The Court of Appeals of Puerto Rico recently upheld a lower court's decision to dismiss a medical malpractice case. This ruling affects the family of Juana M. Santiago Román, who passed away after receiving treatment at Hospital El Maestro. The court found that the claim was filed too late, a decision that has significant implications for how medical malpractice cases are pursued in Puerto Rico.
The case, titled Jorge R. Castro Reyes and Aidza Santiago Román, Por Si Y en Representación De Su Madre, Juana M. Santiago Román (Qepd) v. Hospital El Maestro, was filed under docket number TA2026AP00083. It began when the plaintiffs alleged that their mother received inadequate medical care at the hospital, leading to her death. The court's ruling emphasizes the importance of timely legal action in medical malpractice claims.
Background
The plaintiffs, Jorge R. Castro Reyes and Aidza Santiago Román, filed the lawsuit on behalf of their deceased mother, Juana M. Santiago Román. They claimed that she suffered from respiratory issues and received negligent treatment at Hospital El Maestro on October 10, 2022, which ultimately resulted in her death. They sought damages from the hospital and several medical professionals involved in her care.
The case progressed through the legal system, with the plaintiffs initially filing a complaint that included several defendants, including the hospital and its medical staff. As the case unfolded, the plaintiffs amended their complaint to include the hospital's insurer, The Medical Protective Company (MedPro), after discovering its identity during the discovery phase of the trial.
However, on October 8, 2025, MedPro filed a motion to dismiss the case, arguing that the claim was barred by the statute of limitations. The lower court agreed, leading to an appeal by the plaintiffs.
The Ruling
The Court of Appeals ruled on April 13, 2026, confirming the lower court's decision to dismiss the case against MedPro. The judges on the panel included President Judge Rivera Marchand, Judge Mateu Meléndez, Judge Boria Vizcarrondo, and Judge Robles Adorno. The court stated, "The action against MedPro was prescribed, as the claim was not filed within the applicable one-year statute of limitations."
The court found that the plaintiffs did not properly notify MedPro of the claim within the required timeframe. The judges noted that the plaintiffs' extrajudicial claim, which they argued interrupted the statute of limitations, was not directed to MedPro and therefore did not meet the legal requirements to halt the clock on the statute of limitations.
Additionally, the court ruled that there was no legal solidarity between the hospital and MedPro that would allow the plaintiffs to extend the effects of their extrajudicial claim to the insurer. The court stated, "Solidarity must arise expressly from the insurance contract, and such a relationship was not established in this case."
Impact
This ruling has significant implications for future medical malpractice cases in Puerto Rico. It highlights the necessity for plaintiffs to act quickly and ensure that all parties, including insurers, are properly notified within the statute of limitations. Failure to do so could result in the dismissal of their claims, as seen in this case.
The decision also clarifies the legal standards regarding the relationship between hospitals and their insurers. Without clear provisions in the insurance contract establishing solidarity, plaintiffs may find it challenging to hold both parties accountable in malpractice claims. This ruling may discourage some potential plaintiffs from pursuing claims if they fear that procedural missteps could jeopardize their cases.
What's Next
The plaintiffs have the option to appeal this decision to the Supreme Court of Puerto Rico. However, it is unclear whether they will pursue this route. There are no related cases pending that could affect this ruling.