A Puerto Rico court recently ruled in favor of Daisy Y. Perez Amill, an employee who claimed unpaid wages and benefits from her former employer, Manatí Auto, LLC. The Court of Appeals of Puerto Rico reversed a lower court's decision that dismissed her case, stating that her voluntary resignation did not eliminate her right to claim owed compensation. This ruling highlights important protections for employees under labor laws in Puerto Rico.
The case, Daisy Y. Perez Amill v. Manatí Auto, LLC, was filed on May 7, 2026, under docket number TA2026AP00412. It centers around Perez Amill's allegations that she was owed significant wages and benefits despite her resignation from her position as General Manager. The court's decision may have implications for how labor disputes are handled in the future.
Perez Amill worked for Manatí Auto, LLC, and D’Show Group LLC from September 15, 2020, until her resignation on December 26, 2025. According to her claims, she was entitled to a monthly salary of $5,000, various bonuses, and reimbursements for expenses incurred on behalf of the company. She alleged that her employer failed to pay her for several pay periods and unilaterally cut her compensation without notice. After her resignation, she sought to recover over $10,000 in unpaid wages and other benefits.
The dispute escalated when Perez Amill filed a complaint under Puerto Rico's Law No. 2, which provides a summary procedure for labor claims. She argued that her employer's failure to respond to her complaint within the legal timeframe should result in a judgment in her favor. However, the lower court dismissed her case, stating that her voluntary resignation meant there was no unjust dismissal, which would typically fall under the protections of the law.
The Court of Appeals, led by Judge Hernández Sánchez and joined by Judges Rivera Torres and Marrero Guerrero, reviewed the case and found that the lower court had erred in its interpretation of the law. The court stated, "The fact that the appellant was not dismissed does not eliminate or extinguish potential independent claims for earned wages, accumulated benefits, bonuses, reimbursements, or other compensation allegedly owed for services already rendered." This clarification is crucial as it broadens the scope of claims that can be pursued under Law No. 2.
The court emphasized that the purpose of Law No. 2 is to provide a swift judicial mechanism for resolving labor disputes, particularly those related to wages and benefits. The ruling highlighted that the law applies not only to cases of unjust dismissal but also to any claims for compensation owed to employees. The court's decision effectively allows Perez Amill's claims to proceed, reversing the dismissal and ordering the lower court to address her request for a default judgment due to her employer's failure to respond.
This ruling is significant for employees in Puerto Rico, as it reinforces their rights to seek compensation for unpaid wages and benefits, regardless of their employment status. It clarifies that voluntary resignation does not negate the possibility of claiming owed compensation, thus ensuring that employees have a legal avenue to address grievances against employers.
Going forward, this decision may set a precedent for similar cases in Puerto Rico, encouraging employees to pursue claims for unpaid wages and benefits without fear of dismissal based solely on their resignation status. It underscores the importance of compliance with labor laws by employers and the need for timely responses to employee claims.
As for the next steps, the case will return to the lower court for further proceedings. The lower court is now tasked with addressing Perez Amill's request for a default judgment against her former employer, which could lead to a resolution of her claims for unpaid wages and benefits. It remains to be seen whether the employers will contest the ruling or seek to settle the matter out of court.