The Puerto Rico Court of Appeals recently ruled on a significant case involving the Municipio de San Lorenzo and Carlos Porfirio MartÃnez Zayas. The court's decision, issued on July 31, 2026, overturned a lower court's ruling regarding the expropriation of a property in San Lorenzo. This ruling affects property owners and municipalities across Puerto Rico, clarifying the legal standards for expropriation and compensation.
The case, known as Municipio De San Lorenzo v. Carlos Porfirio MartÃnez Zayas Y Otros (Docket TA2026AP00713), began when the Municipio de San Lorenzo sought to acquire a property located at 116 Eugenio Sánchez López Street, claiming it was a public nuisance. The municipality argued that the property was necessary for public use and estimated its value at $78,300. However, the lower court ordered the transfer of the property to the municipality only after the payment of $49,473.63 in compensation.
The Municipio de San Lorenzo appealed this decision, arguing that it should not have been required to pay compensation upfront since the property was declared a public nuisance. The municipality contended that the obligation to pay only arises when the property owners respond to the legal action, which did not happen in this case.
The dispute escalated through various procedural steps in the lower court, where the municipality faced challenges in properly notifying the property owners. After multiple attempts to serve notice, the court ultimately ruled in favor of the municipality but imposed conditions that required compensation before the property transfer.
In its ruling, the Court of Appeals, led by Judge Lotti RodrÃguez and a panel that included Judges Grana MartÃnez, Ronda Del Toro, and Sánchez Báez, found that the lower court had erred in its decision. The court stated, "In absence of proof of publication, the edict service was not perfected, and the primary court did not acquire jurisdiction over the parties involved." This means that the lower court's ruling was invalid due to improper notification of the property owners.
The Court of Appeals emphasized the importance of proper notification in legal proceedings, especially in expropriation cases. The court noted that the municipality failed to demonstrate that it had followed the necessary legal procedures to notify the property owners adequately. As a result, the court ruled that the lower court's decision was null and void.
This ruling has significant implications for municipalities in Puerto Rico. It clarifies that proper notification is essential for the court to have jurisdiction over property owners in expropriation cases. If municipalities do not follow the correct procedures, they risk having their expropriation efforts invalidated.
Going forward, this decision sets a precedent for how expropriation cases will be handled in Puerto Rico. Municipalities must ensure they comply with all legal requirements for notification and compensation to avoid similar outcomes in the future. This ruling reinforces the rights of property owners and the importance of due process in legal proceedings.
As for what comes next, the case has been sent back to the lower court for further proceedings. The Municipio de San Lorenzo may still pursue expropriation, but it will need to ensure proper notification and potentially address any other legal requirements before moving forward. There is no indication in the court filing that the decision will be appealed further.











