The Puerto Rico Court of Appeals has reversed a lower court's ruling that favored Jesiel Manuel Casillas Flores in a sexual assault case. This decision, issued on September 4, 2026, has significant implications for how evidence is handled in criminal proceedings, particularly regarding the rights of defendants to access potentially exculpatory evidence.

The case, docketed as TA2026CE00963, began when the Public Ministry charged Casillas Flores with sexual assault against a minor and other related offenses. The court's ruling affects not only Casillas Flores but also sets a precedent for future cases involving the preservation and availability of evidence.

Background

The dispute centers around allegations that Casillas Flores committed sexual acts against a girl under the age of 13 at the San Jorge Hospital on September 30, 2023. Following the charges, Casillas Flores sought to obtain evidence from the Public Ministry to prepare his defense, specifically requesting video footage from security cameras at the hospital.

During the preliminary hearing, Casillas Flores's defense team argued that the evidence was incomplete and potentially exculpatory. They claimed that the absence of crucial video footage could undermine the prosecution's case, leading to a violation of his due process rights. The lower court initially ruled in favor of the defendant, citing a precedent from a previous case, Pueblo v. Vélez Bonilla, which established that the loss of evidence could warrant a presumption in favor of the accused.

The Ruling

The Appeals Court, led by Judge Mateu Meléndez, concluded that the lower court erred in applying a presumption in favor of Casillas Flores. The court found that the evidence in question was never under the custody or control of the state, which negated the basis for the presumption. The ruling stated, "the court erred in applying a presumption favorable to the respondent without establishing that the evidence was under the control of the state."

The Appeals Court emphasized that for the presumption to apply, it must be demonstrated that the evidence was lost or destroyed while in the state's custody. Since the evidence was delivered incompletely by the hospital, the Appeals Court determined that the state could not be held liable for negligence in preserving it.

Impact

This ruling has significant implications for future criminal cases in Puerto Rico. It clarifies the responsibilities of the state regarding evidence preservation and reinforces the need for defendants to establish that evidence was under state control to claim a violation of due process. The court's decision may affect how lower courts handle similar cases, particularly those involving the loss of potentially exculpatory evidence.

Moreover, this ruling could influence the strategies of defense attorneys in future cases, as they may need to demonstrate more clearly that evidence was mishandled by the state to invoke protections under due process rights. The decision underscores the importance of thorough evidence management in criminal investigations.

What's Next

It remains to be seen whether Casillas Flores will appeal this ruling to a higher court. The Appeals Court's decision sets a new standard for evidence handling in Puerto Rico, potentially affecting other pending cases involving similar issues. Details regarding any potential appeals or related cases were not available in the court filing.