A recent ruling by the Court of Appeals of Puerto Rico has significant implications for property ownership disputes in the territory. The court reversed a lower court's decision that denied a couple's request to establish their ownership of a property not registered in the Property Registry. This ruling affects Miguel Ángel Rodríguez Acevedo and Janet López Guardarrama, who sought to have their claim to the property recognized legally.
The case, filed under docket number TA2026CE00995, arose from the couple's efforts to register a property they claimed to have possessed for over 18 years. Their request was initially denied by the lower court, which stated that their petition did not meet the necessary legal requirements. The Appeals Court's decision now allows the couple's claim to be reconsidered under the correct legal framework.
Background
The dispute began when Rodríguez Acevedo and López Guardarrama filed a "Petición Jurada" (sworn petition) on October 1, 2025, to establish their ownership of a property located in San Juan, Puerto Rico. They argued that they obtained ownership through a private contract dating back to September 10, 2007, and claimed that the previous owner had possessed the property for over 35 years. They contended that their own possession of the property had been public, peaceful, and continuous for more than 18 years, which is a requirement for establishing ownership under Puerto Rican law.
On May 20, 2026, the lower court held a hearing where both parties presented evidence. However, on July 6, 2026, the court issued a ruling declaring that the couple's petition was denied, stating that it did not meet the legal standards required for ownership claims. Following this ruling, the couple filed a "Solicitud de Certiorari" (request for certiorari) with the Court of Appeals, arguing that the lower court had made a legal error by not considering the previous owner's time of possession.
The Ruling
The Court of Appeals, led by Judge Brignoni Mártir and joined by Judges Ronda del Toro and Monge Gómez, reviewed the case and found that the lower court had erred in its decision. The court ruled, "We conclude to issue the present certiorari order and thereby revoke the challenged determination." The Appeals Court emphasized that the lower court should have focused exclusively on the requirements related to the legal concept of the "expediente de dominio" (domain file) as outlined in Articles 185 and 188 of the Property Registry Law.
The Appeals Court clarified that the purpose of the expediente de dominio is to justify ownership and not to declare property rights. The court noted that the lower court had incorrectly integrated the legal concepts of ownership declaration and domain justification, which led to confusion and an erroneous ruling. The Appeals Court mandated that the case be sent back to the lower court for a proper evaluation of the requirements for establishing ownership.
Impact
This ruling has important implications for property ownership claims in Puerto Rico. It clarifies the legal process for individuals seeking to register properties that are not currently listed in the Property Registry. The Appeals Court's decision reinforces the idea that previous ownership claims can be considered when determining current ownership, as long as the legal criteria are met.
Furthermore, the court's ruling highlights the distinction between justifying ownership through the expediente de dominio and declaring ownership through usucapión (adverse possession). This clarification is vital for future cases, as it sets a precedent for how courts should handle similar disputes regarding property claims.
What's Next
The case will return to the lower court, which must now reevaluate the couple's petition in light of the Appeals Court's ruling. The couple may also pursue further legal action if they believe their rights are still not adequately addressed. Details were not available in the court filing regarding any potential appeals or related cases.