The Puerto Rico Court of Appeals recently denied a request for certiorari in the case of Adriana MarÃa Caparrós Jordán v. Pedro Juan Hernández Rivera (Docket TA2026CE00761). The court's decision affects the ongoing divorce proceedings between the two parties, specifically regarding the division of assets and the discovery process related to their marital property.
This ruling is significant because it clarifies the court's stance on the discovery of evidence in divorce cases, particularly when contractual clauses are in dispute. The decision impacts how similar cases may be handled in the future, particularly in terms of the extent of discovery allowed before resolving underlying legal issues.
Background
Adriana MarÃa Caparrós Jordán and Pedro Juan Hernández Rivera were married on August 23, 2008. Prior to their marriage, they entered into a marital capitulations agreement that outlined how their assets would be divided in the event of a divorce. The couple divorced on August 12, 2020, and Caparrós Jordán sought to divide their marital property, claiming they should no longer be considered co-owners of any assets.
Hernández Rivera contested this claim, arguing that they had agreed to a separation of property regime, meaning that any assets acquired individually during the marriage would remain separate. He asserted that the clauses in their marital agreement, particularly clauses 17 and 18, were invalid and should not affect the division of their assets. The case escalated to the Puerto Rico Court of Appeals after Hernández Rivera sought to limit the discovery process, claiming that the validity of the contractual clauses needed to be resolved before proceeding with asset division.
The Ruling
On June 24, 2026, the Puerto Rico Court of Appeals, led by Judge Robles Adorno, along with Judges Bonilla Ortiz and MartÃnez Cordero, issued a ruling denying Hernández Rivera's request for certiorari. The court stated, "the TPI did not abuse its discretion and complied with the regulations related to the discovery of evidence under Rule 23.1 of the Civil Procedure." This ruling means that the lower court's decision to allow broad discovery in the divorce proceedings remains in effect.
The court also highlighted that the discovery process should continue to ascertain the financial status of both parties, regardless of the ongoing dispute about the validity of the marital agreement clauses. The court emphasized that the potential impact of the clauses would be addressed during the asset division phase but should not hinder the discovery process.
Impact
This ruling has important implications for future divorce cases in Puerto Rico. By affirming the lower court's decision to allow extensive discovery, the Appeals Court reinforces the idea that parties in divorce proceedings must provide relevant financial information, even when there are disputes about the validity of contractual agreements. This decision could set a precedent for how similar cases are handled, particularly in terms of the extent of discovery allowed before resolving any underlying legal issues.
Moreover, the court's ruling may encourage parties in divorce cases to be more transparent about their financial situations, knowing that courts can compel the discovery of evidence even when there are disputes about contractual clauses. This could lead to more equitable outcomes in asset division as both parties are required to disclose their financial information.
What's Next
Following this ruling, Hernández Rivera may choose to appeal the decision to the Supreme Court of Puerto Rico, but details about any potential appeal were not available in the court filing. The ongoing case regarding the division of assets will continue in the lower court, where the discovery process will proceed as ordered by the Appeals Court.