The Puerto Rico Court of Appeals ruled on April 20, 2026, to reinstate two workers from the Autoridad de Carreteras y Transportación (ACT) after their dismissal was deemed unjustified. The court's decision emphasizes the importance of due process in administrative actions. This ruling affects Edwin Bones DÃaz and Edgardo L. Zambrana Roig, who were previously terminated for alleged discrepancies in their work hours and travel reimbursements.
The case arose after the ACT accused the two employees of various infractions related to their job performance and travel claims. The workers contested their dismissal through arbitration, which concluded that their termination was not warranted. However, the ACT appealed the arbitration decision, leading to a review by the Court of Appeals.
Background
The Autoridad de Carreteras y Transportación (ACT) is a government agency in Puerto Rico responsible for road maintenance and transportation services. Edwin Bones DÃaz and Edgardo L. Zambrana Roig were employed as heavy equipment operators within this agency. In March and April 2019, the ACT notified both employees of its intention to terminate them due to alleged discrepancies found in an internal audit regarding their work hours and travel reimbursements.
The audit revealed inconsistencies in the time worked by the employees, which led to accusations of negligence and misconduct. Specifically, the ACT claimed that the employees failed to adhere to their work schedules and improperly submitted travel expense claims. Following an administrative hearing, the ACT confirmed their dismissals in June 2019.
In response, the workers, represented by PROSOL-UTIER, the union chapter for the ACT, sought arbitration under their collective bargaining agreement. The arbitration concluded in April 2025, finding that the ACT's actions were unjustified and ordered the reinstatement of both employees with back pay. The ACT, dissatisfied with the arbitration ruling, sought judicial review from the Tribunal de Primera Instancia, which initially upheld the dismissals.
The Ruling
The Puerto Rico Court of Appeals, led by Judge Rivera Marchand, reviewed the case and ruled in favor of the workers. The court stated, "The administrative notifications regarding the intention to dismiss the employees did not comply with due process requirements." The court found that the ACT's actions lacked specificity and clarity regarding the alleged infractions, which ultimately led to a violation of the workers' rights.
Furthermore, the court indicated that the ACT failed to provide sufficient evidence linking the employees to the alleged misconduct. The ruling emphasized that the arbitration process had adequately addressed the issues at hand and that the ACT's appeal did not present valid grounds for overturning the arbitration decision.
Impact
This ruling has significant implications for labor relations and administrative procedures in Puerto Rico. It reinforces the necessity for government agencies to adhere to due process when taking disciplinary actions against employees. The decision also highlights the importance of arbitration as a means of resolving disputes between employers and employees, particularly in the public sector.
By reinstating the workers, the court has set a precedent that emphasizes the need for clear communication and proper documentation in administrative actions. This ruling may encourage other employees facing similar situations to seek arbitration and challenge unjust dismissals, knowing that the courts will uphold their rights to due process.