The Puerto Rico Court of Appeals recently upheld a ruling concerning the unclaimed funds from a bank account belonging to the late Crucita Ocasio Crespo. The court's decision affects the heirs of Ocasio Crespo, who sought to reclaim over $19,000 from the government after the funds were deemed unclaimed by the financial institution. This ruling clarifies the legal processes surrounding unclaimed property and the responsibilities of financial institutions in Puerto Rico.
The case, titled Sucesión De Crucita Ocasio Crespo, Adalberto Hernández Ocasio, Rafael Hernández Ocasio Y Otros v. Comisionado De Instituciones Financieras De Puerto Rico, was filed under docket number TA2026AP00729. It originated when the heirs of Ocasio Crespo filed a lawsuit against the Commissioner of Financial Institutions of Puerto Rico (OCIF) after the funds from her bank account were transferred to the government due to inactivity.
Background
The dispute began when Crucita Ocasio Crespo passed away on May 6, 2015. Following her death, her heirs, including her sisters and nephews, opened her estate and identified a bank account at Banco Popular de Puerto Rico (BPPR) containing $19,261.05. However, on December 10, 2020, BPPR transferred the funds to OCIF, claiming they were unclaimed under the applicable law.
The heirs attempted to reclaim the funds within three years, as stipulated by the law governing unclaimed property in Puerto Rico. They made several attempts to communicate with OCIF, including a phone call on November 17, 2021, and an email sent on May 5, 2022. However, due to the incapacity and eventual death of two heirs, they could not complete the necessary paperwork within the required timeframe.
On June 4, 2026, the lower court ruled in favor of OCIF, granting their motion for summary judgment and dismissing the heirs' claim. The court found that the heirs failed to complete their claim within the legally required 180 days after being notified of the incomplete application.
The Ruling
The Court of Appeals, which included judges Bonilla Ortiz, MartÃnez Cordero, and Robles Adorno, upheld the lower court's decision. The ruling confirmed that the heirs did not meet the necessary legal requirements to reclaim the funds. The court stated, "the Sucesión Ocasio Crespo understood that it interrupted the term by submitting the request for the withdrawal of the funds, but did not complete that request within the term of one hundred eighty (180) days to claim the abandoned or unclaimed money from OCIF."
The court emphasized that the time limit for completing the claim began once the heirs were notified of the incomplete application. Since they failed to meet the deadline, OCIF was within its rights to transfer the funds to the Department of Treasury after three years.
Impact
This ruling has significant implications for the heirs of deceased individuals in Puerto Rico seeking to reclaim unclaimed funds. It clarifies the importance of adhering to strict deadlines and the procedures required to reclaim such funds. The court's decision reinforces the notion that financial institutions and regulatory bodies like OCIF are not liable for funds that have been legally classified as abandoned after the prescribed time limits.
Additionally, the ruling highlights the distinction between prescription and caducity in legal terms. The court confirmed that the three-year period for reclaiming unclaimed funds is a caducity term, meaning it cannot be interrupted once it has expired. This distinction is crucial for future cases involving unclaimed property in Puerto Rico.
What's Next
The heirs may consider appealing the decision to a higher court, but details were not available in the court filing regarding their intentions. This case serves as a reminder for individuals to stay informed about their rights and the legal processes surrounding unclaimed property, especially in cases involving deceased relatives.