The Puerto Rico Court of Appeals recently upheld a lower court's decision regarding child support payments in the case of Daianie Pérez Quintana v. Félix Alexis Hernández Muñiz, docket number TA2026AP00291. The court ruled that the lower court correctly determined the child support obligations based on the shared custody arrangement between the parents. This decision affects both parties involved and sets a precedent for future child support cases in Puerto Rico.
In this case, Daianie Pérez Quintana, the appellant, sought to overturn a February 2, 2026 resolution from the Superior Court of Aguadilla. The resolution denied her requests for a basic child support payment and a supplemental housing allowance from Félix Alexis Hernández Muñiz, the appellee. The court's ruling is significant as it clarifies how child support obligations are determined in cases of shared custody.
The dispute began when Pérez Quintana filed a child support claim against Hernández Muñiz on September 28, 2021. At that time, their child was only seven months old, and no child support had been established. Pérez Quintana requested both basic and supplemental child support payments. An examiner conducted a hearing and recommended a provisional child support payment, which the court approved. However, the case saw multiple delays and rescheduling before a final child support amount was determined.
On November 22, 2022, the examiner issued a final report recommending a child support payment of $438.30 per month, which included basic support, supplemental housing, and additional costs for childcare. The court accepted this recommendation, but Hernández Muñiz later filed for an adjustment in child support based on a parallel custody case. He argued that the shared custody arrangement allowed him to spend a significant amount of time with their child, which should affect the support calculation.
The lower court's decision to adjust the child support payments was based on the finding that both parents shared custody equally, leading to the elimination of the basic support payment. Pérez Quintana disagreed with this assessment and filed a motion for reconsideration, arguing that Hernández Muñiz did not spend equal time with their child.
On May 11, 2026, the Puerto Rico Court of Appeals, led by Judge Aldebol Mora, along with Judges Brignoni Mártir and Salgado Schwarz, issued a ruling confirming the lower court's decision. The court stated, "The obligation of parents to support their minor children is part of the right to life enshrined in the Constitution of Puerto Rico." This ruling emphasizes the importance of ensuring that child support obligations are met in accordance with the best interests of the child.
The court also noted that the lower court had acted correctly in determining that the child support payments should be eliminated based on the shared custody arrangement. The ruling highlighted that the lower court's interpretation of the custody arrangement, which was determined to be equal, deserved deference and was not subject to alteration by the appellate court.
This ruling has significant implications for future child support cases in Puerto Rico. It clarifies that when parents share custody equally, the basic child support obligations may be adjusted or eliminated. This decision reinforces the legal framework surrounding child support in cases of shared custody, making it clear that the time spent with each parent can directly impact support calculations.
Looking ahead, it remains to be seen whether Pérez Quintana will seek further legal recourse. The court's decision can potentially be appealed to the Supreme Court of Puerto Rico, but details were not available in the court filing regarding any plans for further appeal. The outcome of this case may influence similar disputes in the future, particularly those involving shared custody arrangements and child support calculations.