The Supreme Court of Puerto Rico has issued a significant ruling regarding the appeal process in eviction cases. The court determined that parties cannot seek to appeal interlocutory decisions in summary eviction procedures. This ruling affects landlords and tenants involved in eviction disputes, clarifying the legal framework for handling such cases.
The case, López Torres Y Otros v. Hogar Sanación, LLC Y Otros (Docket CC-2025-0588), arose from a dispute between Adalberto López Torres and his sisters, who are the petitioners, and Hogar Sanación, LLC, the respondent. The petitioners claimed ownership of two urban properties in Humacao and alleged that Hogar Sanación failed to pay rent and unlawfully subleased the properties.
The petitioners filed a summary eviction and monetary claim against Hogar Sanación on April 17, 2024. They sought to evict the company and recover unpaid rent totaling $34,000, along with additional penalties and legal fees. In response, Hogar Sanación contested the claims, arguing that the petitioners had breached the lease agreement and sought to convert the summary eviction process into an ordinary one, citing complex legal issues that required more thorough examination.
The case progressed through the judicial system, with the First Instance Court initially denying Hogar Sanación's request to convert the summary eviction to an ordinary procedure. The court ruled that the complexities raised by Hogar Sanación did not warrant such a conversion. Dissatisfied with this decision, Hogar Sanación appealed to the Appeals Court, which ultimately reversed the First Instance Court's ruling, allowing the case to proceed as an ordinary procedure.
In response, the petitioners sought a certiorari from the Supreme Court, arguing that the Appeals Court acted without jurisdiction in reviewing the interlocutory decision of the First Instance Court. They contended that the summary eviction process should not allow for the appeal of such decisions, which are meant to expedite the eviction process.
On June 23, 2026, the Supreme Court of Puerto Rico ruled that the review of an interlocutory decision in a summary eviction procedure is incompatible with the legislative intent to expedite such processes. The court stated, "the review through a certiorari of an interlocutory determination is incompatible with the summary eviction process and with the legislator's intention to impart agility to the process."
The court emphasized that the conversion of a summary eviction to an ordinary procedure rests within the sound discretion of the judge. The ruling underscored that the summary eviction process is designed to be swift and efficient, and allowing interlocutory appeals would undermine that goal.
This decision clarifies the legal landscape for eviction cases in Puerto Rico, reinforcing the notion that parties must wait for a final judgment in summary eviction cases before pursuing appeals. The ruling is expected to streamline eviction proceedings, making it more challenging for tenants to delay the process through interlocutory appeals.
Going forward, this ruling will impact landlords and tenants in Puerto Rico by setting a clear precedent regarding the appeal process in summary eviction cases. It underscores the importance of resolving eviction disputes quickly while maintaining the legal rights of both parties.
As for next steps, it remains to be seen whether Hogar Sanación will pursue further legal action following this ruling. They may seek to address the underlying issues in the ordinary procedure now that the Supreme Court has clarified the appeal process. The court's decision may also prompt discussions about potential legislative changes to further refine the eviction process in Puerto Rico.