We, LLC v. One Asia Puerto Rico, Inc
KLAN202500124
| Tribunal De Apelaciones De Pue... | Mar 26, 2025Background
- WE, LLC filed a lawsuit for collection of $37,000 against One Asia Puerto Rico, Inc. and related parties, alleging debt for advances on goods.
- The defendants moved to dismiss, arguing that the complaint lacked specific factual allegations to support a remedy and was deficient in service.
- WE, LLC proposed to amend its complaint, but the trial court found that even the amended version lacked sufficient specific allegations and justified dismissal.
- Judgment dismissing the complaint was entered on December 11, 2024, and a motion for reconsideration was denied on January 14, 2025.
- WE, LLC appealed, but paid the required filing fees one day after the 30-day appellate deadline, not perfecting the appeal in time.
- The Appellate Court considered whether it had jurisdiction, ultimately concluding the appeal was untimely and dismissing for lack of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred in dismissing the complaint for lack of specific factual allegations | WE, LLC argued the (amended) complaint included sufficient specifics regarding the debt owed | One Asia argued the complaint remained conclusory and insufficient, even as amended | Dismissal was justified due to insufficient allegations |
| Whether the appeal was timely and perfected with proper payment of fees | WE, LLC argued that the late payment did not prejudice the appellee and they had no intent to defraud, with the appeal otherwise timely submitted | One Asia argued jurisdictional deadline requires both filing and paying fees within 30 days; a late fee means a late (untimely) appeal | The appeal was untimely because the filing fee was not paid within the 30-day period, depriving the court of jurisdiction |
| Whether defects such as late payment of appellate fees can be excused if no prejudice is shown | WE, LLC argued there was no harm to the other party and notification was timely | One Asia: strict jurisdictional rules apply regardless of prejudice or notification | Strict compliance required; lack of prejudice is irrelevant |
| Whether the appellate court can proceed without jurisdiction on a late filing | WE, LLC urged flexibility on procedural technicalities | One Asia insisted dismissal is mandatory if the appeal is untimely | Court must dismiss for lack of jurisdiction, no discretion |
Key Cases Cited
- Administración de Terrenos de Puerto Rico v. Ponce Bayland Enterprises, Inc., 207 DPR 586 (Puerto Rico 2021) (reiterating that jurisdiction is a primary threshold issue for courts)
- Ruiz Camilo v. Trafon Group, Inc., 200 DPR 254 (Puerto Rico 2018) (affirming duty to analyze jurisdiction before reaching merits)
- Yumac Home v. Empresas Masso, 194 DPR 96 (Puerto Rico 2015) (appeal filed after the jurisdictional deadline must be dismissed)
- S.L.G. Szendrey-Ramos v. F. Castillo, 169 DPR 873 (Puerto Rico 2007) (late appeals deprive appellate courts of jurisdiction)
- Maldonado v. Pichardo, 104 DPR 778 (Puerto Rico 1976) (judicial filings without required fees are null and void)