Sepulveda Carrero, Jaime Noel v. Exparte, KLCE202301368

Jaime Noel Sepúlveda Carrero sought to perpetuate the fact that he is also known as "Jaime Noel de Sepúlveda Carrero" via an Ad Perpetuam Rei Memoriam proceeding in Puerto Rico’s courts.
The trial court dismissed the original request, citing lack of jurisdiction to order a name change in the Washington State Demographic Registry, but the Court of Appeals clarified that the lower court could determine whether petitioner was known by the alternate name.
On remand, an evidentiary hearing was held, with documentary and testimonial evidence offered by Sepúlveda Carrero. The state participated and cross-examined witnesses.
The trial court found insufficient evidence, documentary or testimonial, to establish that the petitioner was known as "Jaime Noel de Sepúlveda Carrero."
Sepúlveda Carrero appealed, alleging errors in the lower court’s handling of evidence, application of procedural rules, and evaluation of the testimony.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in denying the perpetuation of the fact that petitioner is known as "Jaime Noel de Sepúlveda Carrero"	Sepúlveda asserted evidence established he was known by that name	State, through the Public Prosecutor, argued evidence did not conclusively support this claim	Court held no clear error in trial court’s assessment; sustained denial
Whether the court misapplied Ad Perpetuam Rei Memoriam requirements	Petitioner argued the legal standard was mistakenly raised or misunderstood by trial court	State maintained the proper evidentiary and legal standards were followed	Court found no misapplication of law or procedure
Whether the trial court erred in its evaluation of the presented evidence	Sepúlveda argued the testimonial and documentary evidence sufficed	State insisted evidence was insufficient and inconsistent	Court deferred to trial judge’s credibility determinations; found no basis for reversal
Whether exclusion of additional evidence (testimony, children’s birth certificates) was erroneous	Argued these exclusions prejudiced his case and merited reversal	Argued that proper procedure for offering evidence was not followed by petitioner	Court found he failed to meet threshold for challenging exclusion; no reversible error

Rivera v. Corte, 68 DPR 673 (explains the nature of voluntary jurisdiction acts)
Ex parte Pérez, 65 DPR 938 (describes the purpose and mechanics of Ad Perpetuam Rei Memoriam)
Rosado v. Acevedo Marrero, 196 DPR 884 (addresses deferential appellate review of trial court credibility determinations)
Dávila Nieves v. Meléndez Marín, 187 DPR 750 (clarifies standards for appellate intervention in factual findings)
Trinidad v. Chade, 153 DPR 280 (affirms deference to trial judge’s credibility assessments)