The Puerto Rico Court of Appeals recently reversed a lower court ruling in the case of Consejo De Titulares Condominio Bahía Marina I v. Krystal Alexandra Campis Berríos, docket number TA2026AP00513. This decision affects how disputes over condo fees and legal representation are handled in the future. The case highlights the importance of proper legal procedures and the rights of parties involved in civil litigation.
In this case, Krystal Campis Berríos, the appellant, challenged a ruling from the First Instance Court of Fajardo that ordered her to pay nearly $24,000 in overdue condo fees and legal costs. The court's decision to impose a penalty on her legal representative for failing to adhere to court procedures led to a series of events that culminated in the appeal.
The dispute began on October 7, 2024, when the Consejo de Titulares Condominio Bahía Marina I filed a lawsuit against Campis Berríos for unpaid maintenance fees and communal insurance for her apartment. After several procedural incidents, a hearing was set for December 1, 2025. However, on November 13, 2025, Campis Berríos's attorney requested a postponement of the hearing due to prior professional commitments outside Puerto Rico. The court denied this request and imposed a $250 fine on the attorney for attempting to reschedule the hearing.
Following the imposition of the fine, the court warned that failure to pay would result in a notation of rebellion against Campis Berríos. When the fine was not paid, the court marked her as rebellious, which ultimately led to the final judgment against her on April 16, 2026. The court ordered her to pay $23,996.63, plus interest and legal costs.
Campis Berríos appealed the ruling, arguing that the First Instance Court erred by issuing a judgment after marking her as rebellious without adequate notice. The court's panel, consisting of judges Rodríguez Casillas, Barresi Ramos, and Santiago Calderón, reviewed the appeal.
The court ruled that the First Instance Court had indeed erred in its procedures. Judge Santiago Calderón stated, “It is unjust that the appellant was penalized due to inadequate notification from the court, which prevented her from correcting the omission and thus avoid the violation of her due process rights.” The court emphasized that the imposition of rebellion must be accompanied by proper notice and opportunity to comply with court orders.
As a result, the Court of Appeals reversed the lower court’s final ruling. It declared the rebellion notation against Campis Berríos null and void and ordered the case to be sent back to the First Instance Court for further proceedings. The court also upheld the $250 fine imposed on her attorney.
This ruling has significant implications for future cases involving similar disputes over condo fees and the legal responsibilities of attorneys. It reinforces the necessity for courts to provide proper notification and due process before imposing severe penalties like rebellion. The decision underscores that parties must be given a fair chance to respond to court orders and that procedural missteps can have serious consequences.
Moving forward, this case may influence how courts handle disputes involving condo fees and the conduct of legal representatives in Puerto Rico. It highlights the importance of adhering to procedural rules and ensuring that all parties are treated fairly in the legal process.
As for what’s next, the case has been sent back to the First Instance Court for further proceedings, allowing both parties to present their arguments and defenses regarding the original dispute. There is no indication that this decision will be appealed further, but the legal landscape regarding condo disputes may evolve based on the outcomes of this case.