The Puerto Rico Court of Appeals recently ruled in favor of María Victoria Berríos Rosa, who filed a personal injury lawsuit against Farmacia San Carlos III, Inc., and several other parties. The court's decision, issued on June 30, 2026, reverses a lower court's summary judgment that dismissed Berríos Rosa's claims, allowing her case to proceed. This ruling is significant as it addresses the responsibilities of property owners and tenants regarding safety conditions.
Berríos Rosa's case began on March 15, 2023, when she alleged that she suffered injuries after tripping over an uneven surface outside the pharmacy. The incident occurred on February 7, 2023, when she parked her vehicle and fell while approaching the store. As a result of the fall, she sustained multiple injuries, including a fractured humerus, and sought damages for her physical injuries and mental anguish.
The parties involved in this case include Berríos Rosa, the pharmacy, its insurance companies, and individuals associated with the property. After Berríos Rosa filed her initial complaint, the pharmacy and its co-defendants denied responsibility, claiming that the accident was due to her own actions and that they had no liability for the incident. They argued that the uneven surface was a structural issue for which the property owner, Reinaldo Navarro Caussade, was responsible.
The case progressed through the legal system, with Berríos Rosa amending her complaint to include additional defendants, including Navarro Caussade and another individual, Rodny Navarro González. The pharmacy and its co-defendants eventually filed a motion for summary judgment, arguing that there were no genuine issues of material fact and that they should be dismissed from the case.
On May 18, 2026, the lower court granted the summary judgment, dismissing Berríos Rosa's claims against the pharmacy and the other defendants. Berríos Rosa appealed this decision, claiming that the court erred in its judgment by not allowing her to present evidence and by making determinations about credibility without a trial.
The Court of Appeals, led by Judge Monge Gómez, reviewed the case and found that the lower court had made errors in its ruling. The court noted, "the documents that obran en el expediente, lejos de eliminar toda controversia material de hechos, plantean cuestiones sustanciales respecto a quién correspondía el mantenimiento y la seguridad del área donde alegadamente se encontraba el desnivel que ocasionó la caída de la señora Berríos Rosa." This means that there were still significant questions about who was responsible for maintaining the safety of the area where Berríos Rosa fell.
The appellate court emphasized that the existence of a contractual relationship between the property owner and the tenant, which included obligations to maintain safety, created a genuine issue of material fact that warranted further examination in court. The court stated that the lower court should not have dismissed the claims without allowing for a full trial to assess the evidence.
This ruling is important for future cases involving personal injury claims related to property conditions. It reinforces the principle that property owners and tenants may share responsibilities for maintaining safe environments for visitors. The court's decision allows Berríos Rosa's case to move forward, meaning she will have the opportunity to present her evidence and arguments in court.
Moving forward, this ruling could impact similar cases in Puerto Rico, as it clarifies the legal standards regarding liability in personal injury claims. It emphasizes the need for courts to carefully consider the facts and circumstances surrounding each case, particularly when determining liability based on contractual obligations and property maintenance.
As for next steps, the case will return to the lower court for further proceedings. The pharmacy and its co-defendants may still seek to appeal the appellate court's decision, but details were not available in the court filing regarding any pending appeals or related cases.