The Puerto Rico Court of Appeals issued a significant ruling on July 28, 2026, regarding child custody and support in the case of Paola Nicole DÃaz Santiago v. Gregory Laboy Serrano (Docket TA2026CE00887). This decision impacts parents navigating custody disputes and child support modifications in Puerto Rico. The court clarified the jurisdictional boundaries between the judicial system and the Administration for the Support of Minors (ASUME), which oversees child support matters.
The case arose when Paola Nicole DÃaz Santiago sought sole custody of her four-year-old daughter and requested a review of the child support payments established by ASUME. DÃaz Santiago argued that her circumstances had changed since the initial support order, as her daughter had begun school and her ex-partner's income had increased. The lower court had previously ruled that any modifications to child support must be handled exclusively by ASUME, leading DÃaz Santiago to appeal that decision.
The parties involved in this case are Paola Nicole DÃaz Santiago, the petitioner, and Gregory Laboy Serrano, the respondent. The dispute centers on the jurisdiction over child support modifications and custody arrangements. The case reached the Court of Appeals after DÃaz Santiago's request for a review of the child support payments was denied by the lower court, which maintained that ASUME had exclusive jurisdiction over such matters.
The Court of Appeals, led by Judge Pagán Ocasio, reviewed the lower court's decision and determined that it had erred in concluding that ASUME held exclusive jurisdiction over the modification of child support payments. The court stated, "the forum in which the initial claim is filed acquires exclusive jurisdiction to set a child support order. However, once a determination has been made, both the First Instance Court and ASUME have concurrent jurisdiction to address subsequent matters related to that obligation." This ruling emphasizes that both the judicial and administrative bodies can address child support issues after the initial order is established.
The court's ruling highlighted the importance of considering the best interests of the child and the principle of procedural economy. The court noted that the lower court failed to provide a specific justification for referring the case to ASUME, which was a requirement based on previous rulings. The Appeals Court concluded that the lower court's decision to limit jurisdiction solely to ASUME was incorrect and did not consider the potential benefits of addressing the issues within the judicial system.
This ruling is significant for parents involved in similar custody and support disputes in Puerto Rico. It clarifies that both the courts and ASUME can handle modifications to child support, allowing for more flexibility in addressing changes in circumstances. This decision may lead to more efficient resolutions for families, as it allows for the possibility of handling related custody and support matters within the same judicial forum.
The ruling also sets a precedent for future cases involving child custody and support in Puerto Rico. It reinforces the idea that courts must carefully consider jurisdictional issues and the best interests of the child when determining the appropriate forum for resolving disputes. This decision could influence how similar cases are handled moving forward, ensuring that parents have access to the necessary legal resources to address their situations effectively.
Looking ahead, the case can potentially be appealed to the Puerto Rico Supreme Court, but details on whether the respondent plans to pursue further legal action were not available in the court filing. This ruling will likely impact ongoing and future cases involving child custody and support in Puerto Rico, as it clarifies the jurisdictional landscape and emphasizes the importance of considering the child's best interests.











