The Puerto Rico Court of Appeals recently ruled against a family appeal concerning the guardianship of an elderly man suffering from Alzheimer's disease. The court's decision affects the family members involved, particularly Carmen Luz Díaz Hernández, who sought to be appointed as the guardian. This ruling is significant as it addresses issues of incapacity and the appointment of guardians in cases involving vulnerable individuals.
The case, titled Carmen Luz Díaz Hernández Exparte; Marellys Díaz Hernández, Ángel L. Díaz Hernández, and Pedro Díaz Hernández, was filed under docket number TA2026CE00751. It centers on a dispute over the appointment of a guardian for Rafael Díaz Boria, the father of Carmen Luz Díaz Hernández, who suffers from severe health issues, including Alzheimer's and dementia.
Carmen Luz Díaz Hernández filed a petition on November 15, 2024, to declare her father incapacitated and to appoint herself as his guardian. She argued that her father's health had deteriorated significantly, affecting his cognitive functions and ability to manage his personal affairs. However, on May 22, 2025, her siblings—Marellys, Ángel L., and Pedro Díaz Hernández—filed a motion opposing her appointment. They claimed that Carmen Luz had restricted access to medical information and had taken control of their father's finances without proper authority.
The case made its way through the Puerto Rican judicial system, leading to a hearing on May 4, 2026, where the court qualified Dr. Víctor J. Lladó, a psychiatrist, as an expert witness. Following the hearing, Carmen Luz's siblings filed a motion for reconsideration, arguing that Dr. Lladó was not qualified to testify about Alzheimer's disease. They contended that his lack of familiarity with current diagnostic guidelines rendered his testimony invalid.
On June 12, 2026, the Puerto Rico Court of Appeals, presided over by Judge Barresi Ramos, along with Judges Rodríguez Casillas and Santiago Calderón, issued a resolution denying the appeal. The court stated, "We find that the petitioners have not demonstrated that the lower court acted with bias, prejudice, or made a substantial error in interpreting or applying any procedural or substantive law." The court emphasized that the lower court's decision to qualify Dr. Lladó was within its discretion and that there was no compelling reason to intervene.
The court's ruling means that the lower court's proceedings will continue, including the scheduled hearings on June 16 and July 9, 2026. The decision underscores the challenges families face in guardianship cases, particularly when there are disagreements among relatives regarding the care and management of an incapacitated individual.
This ruling may have broader implications for similar cases in Puerto Rico, as it reinforces the standards for appointing guardians and the qualifications of expert witnesses in incapacity hearings. Families navigating these complex legal issues may need to carefully consider the qualifications of witnesses and the potential for disputes among relatives.
Looking ahead, the family may still have options for appeal, although the court's decision indicates a strong preference for allowing the lower court to proceed with its hearings. There are no related cases pending at this time that would directly influence this ruling.