The Court of Appeals of Puerto Rico recently ruled against Pedro José Taveras Collazo in his insurance claim against Mapfre Pan American Insurance Company. The court upheld a lower court's decision that dismissed Taveras' case, which was based on alleged unfair practices related to his insurance claim following Hurricane Maria in 2017. This ruling impacts Taveras and others seeking recourse against insurance companies for similar claims.
The case stems from a dispute over damages Taveras claimed occurred to his property during Hurricane Maria, which struck Puerto Rico on September 20, 2017. Taveras, who co-owns the property with Maritza Haddock, argued that the insurance company undervalued the damages and failed to conduct a reasonable investigation. He filed a lawsuit under Law 247-2018, which allows individuals to sue insurance companies for unfair practices. Taveras sought to recover additional funds beyond the payments of $4,735.50 and $3,287.50 that Mapfre had already issued.
In response, Mapfre filed a motion to dismiss, claiming that Taveras' actions had expired under the statute of limitations. The lower court agreed, ruling on April 16, 2026, that Taveras did not provide sufficient evidence to support his claims, leading to the dismissal of his lawsuit. Taveras subsequently appealed the decision.
The Court of Appeals reviewed the case and confirmed the lower court's ruling. The judges noted that the insurance policy clearly stipulated a one-year limit for filing claims, which Taveras failed to meet. They stated, "the cause of action of epígrafe was filed after the applicable prescriptive period had expired." The panel included judges Rivera Marchand, Mateu Meléndez, and Boria Vizcarrondo, with Judge Mateu Meléndez authoring the opinion.
In their ruling, the court emphasized that Taveras did not adequately demonstrate that he had complied with the requirements for notification under Article 27.164 of the Insurance Code. The court found that the notification sent to Mapfre was not in Taveras' name, which was a critical factor in their decision. They concluded that even if the notification had been valid, Taveras' claim was still filed too late.
This ruling is significant as it reinforces the importance of adhering to the time limits set forth in insurance policies and the Insurance Code. It serves as a reminder to policyholders in Puerto Rico about the strict deadlines for filing claims and the necessity of following proper procedures when dealing with insurance companies. The outcome may discourage similar claims from being filed after the expiration of the statutory period.
Looking ahead, Taveras may consider appealing the decision to a higher court. However, details regarding the potential for further legal action were not available in the court filing. The ruling sets a precedent that could influence future cases involving insurance claims and the interpretation of notification requirements under Puerto Rico's Insurance Code.