The Puerto Rico Court of Appeals recently upheld a ruling regarding the division of property in the case of Pilar Pérez Rodríguez v. Onier Izquierdo Camacho, docket number TA2026AP00077. The court confirmed that certain shares in a business, Auto Stop, Inc., were deemed private property and not subject to division in the divorce settlement. This decision affects the former spouses as they navigate the complexities of their divorce settlement and the division of assets acquired during their marriage.
The case originated when Pilar Pérez Rodríguez filed a lawsuit on April 13, 2023, seeking the liquidation of community property following her divorce from Onier Izquierdo Camacho on September 17, 2021. Pérez Rodríguez claimed that during their marriage, they acquired various assets, including shares in Auto Stop, which she alleged she contributed to without receiving payment. She argued that she was unaware of the total assets acquired during the marriage, as Izquierdo Camacho did not keep her informed. Consequently, she sought the court's assistance in liquidating their community property.
In response, Izquierdo Camacho filed a counterclaim, asserting that Pérez Rodríguez's allegations were unfounded and that the liquidation could have been resolved outside of court. He detailed the assets and debts they accumulated during their marriage and requested the court to order the liquidation of their community property. After several procedural incidents, the court held a preliminary conference on April 17, 2024, to determine if there were any credits in the businesses involved and whether Pérez Rodríguez was a shareholder.
On July 23, 2025, Izquierdo Camacho filed a motion for partial summary judgment, claiming that 33% of the shares in Auto Stop were gifted to him by his parents during the marriage. He requested the court to rule that these shares were private property and not subject to division. Pérez Rodríguez opposed this motion, arguing that there were unresolved factual disputes due to Izquierdo Camacho's alleged lack of cooperation during the discovery phase.
On December 4, 2025, the court issued a partial summary judgment in favor of Izquierdo Camacho, ruling that the 33% shares in Auto Stop were indeed private property. The court concluded that there was no substantial factual dispute regarding the ownership of the shares, as the evidence presented clearly demonstrated that they were gifted to Izquierdo Camacho. The court stated, “the evidence presented by Izquierdo Camacho in his request for partial summary judgment clearly shows that his parents gifted him the shares.”
In addition, the court noted that Pérez Rodríguez did not provide admissible evidence to counter this essential fact, limiting her arguments to questioning and assertions that did not meet the specific requirements of the Civil Procedure Rule 36.3. However, the court acknowledged that other issues remained unresolved, such as the potential increase in the shares' value during the marriage and any possible credits owed to the community property.
Pérez Rodríguez appealed the ruling on January 21, 2026, claiming that the court erred in accepting Izquierdo Camacho's motion for partial summary judgment without allowing adequate discovery. She argued that the court abused its discretion by concluding that the shares were private property without a thorough examination of the evidence. In response, Izquierdo Camacho contended that Pérez Rodríguez had ample opportunities to discover evidence and that the court did not abuse its discretion.
After reviewing the case, the court affirmed the lower court’s ruling. The appellate court found no abuse of discretion in the lower court's decision to rule that the shares were private property, as they were donated to Izquierdo Camacho during the marriage. The court emphasized that Pérez Rodríguez's attempts to refute the evidence were insufficient, stating that she relied on generalized allegations without providing substantial evidence.
This ruling has significant implications for the parties involved as they continue to navigate their divorce proceedings. It clarifies the nature of property division in divorce cases, particularly regarding business assets acquired during marriage. The court’s decision reinforces the importance of providing concrete evidence in legal disputes over asset ownership and the division of property.
Looking ahead, it is unclear whether Pérez Rodríguez will seek further appeal options. The court's ruling is final unless a higher court decides to review the case. Additionally, there are no related cases pending at this time, but the outcome may influence future divorce and property division cases in Puerto Rico.