The Puerto Rico Court of Appeals recently ruled on a case involving the Municipality of San Juan and a property owner, Eurípides Ramón Del Villar Rosario, regarding a forced expropriation of land. The court upheld a lower court's decision that dismissed the Municipality's petition for expropriation due to inadequate notification of interested parties. This ruling could have significant implications for how municipalities in Puerto Rico handle property expropriation.

The case, Municipio Autónomo De San Juan v. Eurípides Ramón Del Villar Rosario Y Otros, was filed under docket number TA2026AP00067. The Municipality sought to acquire a property located in Santurce, which had been declared a public nuisance in December 2021. The Municipality argued that the property would be rehabilitated for public use and proposed compensation of $60,000, which was later adjusted to $33,462.11 after deducting taxes and fees.

The dispute arose when María M. López Arroyo, a co-owner of the property, contested the expropriation. She claimed that she had not been properly notified of the public nuisance declaration, which was a prerequisite for the Municipality's expropriation efforts. López Arroyo argued that the expropriation was invalid due to this lack of notification and requested the dismissal of the Municipality's petition.

The case was brought before the Court of First Instance, which ruled in favor of López Arroyo on October 20, 2025. The court found that the Municipality had failed to make reasonable efforts to notify all parties with an interest in the property before declaring it a public nuisance. The Municipality's investigation was limited to information from the Municipal Revenue Collection Center (CRIM) and did not include a thorough search of the property registry, which would have revealed López Arroyo's co-ownership.

Following the lower court's ruling, the Municipality appealed the decision, arguing that the court had erred in its findings. The Municipality contended that the declaration of public nuisance had been final and that it had complied with its notification obligations under the applicable municipal regulations.

On August 10, 2026, the Puerto Rico Court of Appeals issued its ruling. The court confirmed the lower court's decision, stating, "The Municipality did not conduct reasonable efforts to identify and notify all interested parties regarding the property before declaring it a public nuisance." The panel included judges Rivera Marchand, Cruz Hiraldo, and Sánchez Báez, with Sánchez Báez serving as the presiding judge.

The court emphasized that the expropriation process is governed by strict requirements to ensure that all parties with an interest in the property are adequately notified. The court ruled that the Municipality's reliance on limited information from the CRIM was insufficient to fulfill its legal obligations. The ruling underscored the importance of due process in administrative proceedings, particularly when the government seeks to take private property.

This decision has significant implications for municipalities in Puerto Rico, as it reinforces the necessity of thorough and diligent notification processes in property expropriation cases. The ruling may serve as a precedent for future cases, ensuring that property owners are afforded their rights and protections under the law.

Looking ahead, the Municipality of San Juan has the option to appeal the ruling to a higher court, although details regarding any potential appeal were not available in the court filing. The outcome of this case could influence how municipalities approach similar expropriation efforts in the future, emphasizing the need for compliance with notification requirements to avoid legal challenges.