The Puerto Rico Court of Appeals recently ruled on a significant employment contract dispute involving Farel E. Velázquez Gómez and Integrated Security Services, Intl. Inc. The court's decision addresses claims of unpaid commissions and the interpretation of employment contracts. This ruling could impact how similar disputes are handled in the future.
The case, titled Farel E. Velázquez Gómez Y Compulsolutions, LLC. v. Integrated Security Services, Intl. Inc., was filed under docket number TA2026AP00389. It centers around Velázquez's claims against Integrated Security Services (ISS) for unpaid commissions after his employment ended in August 2023. The court's ruling was issued on May 22, 2026, by a panel including Judge Ronda Del Toro, Judge Grana Martínez, and Judge Lotti Rodríguez.
Velázquez worked as the Director of Technical Operations for ISS from July 5, 2021, until August 1, 2023. According to his employment agreement, he was to receive a salary of $42,500 per year, along with a 3% commission on completed projects. Velázquez claimed that he had not received any commissions for several projects he worked on during his employment, totaling $234,385. The projects he mentioned included work for various municipalities and organizations.
In response to Velázquez's claims, ISS argued that all commissions related to the projects had been paid. They contended that the projects listed by Velázquez had begun before he joined the company, thus he was not entitled to any commissions. ISS also raised a defense based on the statute of limitations, asserting that Velázquez's claims were time-barred under the applicable law.
On February 23, 2026, ISS filed a motion for partial summary judgment, arguing that Velázquez's claims regarding unpaid commissions were barred by the one-year statute of limitations for wage claims under Puerto Rico law. The court granted this motion on March 20, 2026, dismissing Velázquez's claims with prejudice, meaning he could not bring the same claims again.
Velázquez appealed this decision, arguing that the lower court had erred in its ruling. He claimed that his request for commissions was based on a breach of contract, not a wage claim, and that the court failed to properly assess when his right to claim the commissions arose.
The Court of Appeals reviewed the case and noted that the lower court had issued a partial judgment without clearly stating that it was a partial ruling. The court stated, "The lower court's judgment lacked the necessary language to indicate that it was a partial ruling, which is required by law." This lack of clarity could affect how the case proceeds in the lower court.
The appellate court confirmed the lower court's ruling regarding the statute of limitations, stating that Velázquez's claims were indeed time-barred. The court explained that since Velázquez's employment ended on August 1, 2023, he had until August 1, 2024, to file his claims. However, he did not file until September 9, 2024, which was too late.
The court emphasized that the nature of Velázquez's claims fell under the employment contract, which is governed by specific statutes. The court found that Velázquez's claims for commissions were essentially wage claims, which are subject to a one-year limitation period. The court stated, "The claims for commissions arise from the employment contract, and therefore, the one-year statute of limitations applies."
This ruling has significant implications for future employment disputes in Puerto Rico. It reinforces the importance of understanding the statute of limitations for wage-related claims and clarifies the interpretation of employment contracts regarding commissions. Employers and employees alike may need to review their agreements and ensure that they are aware of the legal timelines for filing claims.
Looking ahead, Velázquez may have limited options for appeal since the court has confirmed the lower court's ruling. However, the case could still proceed regarding other claims not dismissed by the court. The appellate court's decision does not prevent further litigation on the remaining issues in the case.
In conclusion, the Puerto Rico Court of Appeals' ruling highlights the complexities of employment contracts and the importance of timely legal action in wage disputes. As the legal landscape continues to evolve, both employers and employees should stay informed about their rights and obligations under the law.