The Court of Appeals of Puerto Rico issued a significant ruling on June 12, 2026, regarding an eviction case involving María Delia Bauzá Díaz and Maribel Marrero Matías. The court's decision highlights important jurisdictional issues that arise when a non-resident is involved in legal proceedings in Puerto Rico. This ruling affects landlords and tenants alike, particularly in cases where one party does not reside in the jurisdiction.

The case, filed under docket number TA2026CE00663, began when Bauzá Díaz, a non-resident of Puerto Rico, sought to evict Marrero Matías from a property in Patillas, Puerto Rico. Bauzá Díaz claimed that Marrero Matías had failed to pay rent under a verbal lease agreement. The initial ruling from the lower court ordered Marrero Matías to vacate the property and pay the owed rent. However, the case took a turn when the appeals court identified a jurisdictional issue that had not been addressed in the lower court's proceedings.

The dispute arose when Bauzá Díaz filed a lawsuit for eviction and collection of unpaid rent against Marrero Matías in April 2026. The complaint stated that Bauzá Díaz resided in Florida and had a verbal agreement with Marrero Matías for the rental of the property. The lower court scheduled a hearing for April 27, 2026, where it ruled in favor of Bauzá Díaz, ordering Marrero Matías to vacate the premises. However, Marrero Matías contested the ruling, arguing that Bauzá Díaz lacked the legal standing to file the eviction since she was not the property owner.

After reviewing the case, the Court of Appeals found that the lower court had failed to impose a mandatory bond for non-residents, which is required under Rule 69.5 of the Civil Procedure. This rule stipulates that a non-resident claimant must post a bond to cover potential costs and attorney fees in case the defendant prevails. The court emphasized that this requirement is not discretionary and must be enforced before proceeding with any legal action.

In its ruling, the court stated, "the imposition of the bond for non-residents is a legal imperative that the lower court must comply with before continuing the proceedings." The judges on the panel included Candelaria Rosa, Adames Soto, and Campos Pérez, with Adames Soto serving as the lead judge. The court ordered the lower court to impose the required bond and suspended the original ruling until this condition was met.

This ruling has significant implications for future eviction cases in Puerto Rico, particularly those involving non-resident landlords. The court's decision reinforces the importance of jurisdictional requirements and ensures that non-resident claimants cannot bypass necessary legal procedures. The ruling clarifies that all parties must adhere to the established rules, which aim to protect defendants from potential financial harm when dealing with claimants who do not reside in the jurisdiction.

Going forward, this decision may affect how landlords and tenants approach eviction cases in Puerto Rico. Non-resident landlords must be aware of the bond requirement and ensure compliance with local laws to avoid complications in their legal proceedings. Additionally, this ruling may set a precedent for similar cases in the future, emphasizing the importance of jurisdictional compliance in eviction matters.

As for the next steps, the case will return to the lower court for the imposition of the required bond. If the bond is posted, the eviction proceedings can continue. If not, the case may be dismissed. Legal experts suggest that this ruling could lead to more scrutiny of similar cases involving non-residents, ensuring that all parties are held accountable to the jurisdiction's requirements.