Sindicato de Bomberos Unidos v. Cuerpo de Bomberos, 180 P.R. 723

Consolidated petitions challenge constitutionality of Ley 7 (Mar 9, 2009) and request annulment of layoff notices and reinstatement; issues largely tied to Domínguez Castro v. E.L.A. I and expressly pursued in this proceeding.
SBUPR filed Jan 26, 2010 complaint vs. Puerto Rico Fire Department, Interim Fire Chief, and State; alleged non-simultaneous layoff notices and Sec. 17, Art. III constitutional violation.
SPU filed Jan 5, 2010 complaint vs. several agencies (Education, Family, SSS, DOT, Natural Resources) alleging defective layoff notices and violation of Sec. 17, Art. III.
AC-2010-0018: Federation (FCT) filed Nov 5, 2009 suit against Housing, Recreation & Sports, and the Government alleging defective layoff notices to its members.
Trial court held hearings, issued rulings that layoff notices were defective; appeals followed; consolidated cases ordered on Dec 2, 2010 for common issues.
Court ultimately held Ley 7 constitutional, clarified notice requirements, and remanded CT-2010-0002 for further proceedings; rejected arguments that simultaneity was required and that interims/signature authority invalidated notices.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ley 7 violates the single-subject rule in Sec. 17, Art. III	SBUPR/SPU/FCT assert multiple subjects inside Ley 7	State contends Ley 7 is economically cohesive and directly related to fiscal emergency	Constitutional; Ley 7 relates to a single anticipated subject and passes single-subject test
Whether proportional notice must be simultaneous to employees and union	Notices must be issued simultaneously to employees and their union	Simultaneity not required by Ley 7; letters must meet 30-day rule	Not required; notices must meet 30-day advance, but simultaneity not mandated; union notification may be separate as long as date communicated
Whether Pedro A. Vázquez Montañez had capacity to sign layoff notices	Vázquez Montañez lacked authority to sign as interim Chief	Interim status confers full power to sign; continuity rules apply	Vázquez Montañez had authority to sign; notices valid
Whether defective notice to union affects due process	Union-notice defects violate due process rights	Molini Gronau and related doctrine provide remedies; process intact	Defects do not void layoff; review rights preserved; if timely filed, merits adjudicated
Whether delegation to JREF violates separation of powers	Delegation to JREF is excessive	Delegation with adequate guidelines is constitutionally valid	Delegation valid; laws provide sufficient guidance and safeguards; not an improper power grab

Domínguez Castro v. E.L.A. I, 178 D.P.R. 1 (2010) (extensive discussion of due process, state police power, and emergency fiscal measures in sustenance of public welfare)
Herrero v. E.L.A., 179 D.P.R. 277 (2010) (regla de un solo asunto; interpretation guiding principles; riders and logrolling concepts)
Laboy v. Corp. Azucarera Sauri & Subirá, 65 D.P.R. 422 (1945) (single-subject rule; title must express the matter under regulation)
Comisionado Seguros P.R. v. Integrand, 173 D.P.R. 900 (2008) (interpretation in insurance; statutory construction harmonized with context)
Medina Sánchez v. Swiss Chalet, 178 D.P.R. 363 (2010) (jurisdictional and interpretive analysis in regulatory disputes)
Molini Gronau v. Corp. P.R. Dif. Púb., 179 D.P.R. 674 (2010) (notificación defectuosa; remedial path for employees; incursion on due process)