The Puerto Rico Supreme Court issued a significant ruling on May 18, 2026, in the case of Javier Flores Reyes v. Prestress Manufacturing Corp. (Docket CC-2025-0135). The court addressed important issues regarding labor law procedures, specifically the compatibility of reconsideration motions within expedited labor proceedings. The decision affects employees and employers navigating similar labor disputes in Puerto Rico.
In this case, Javier Flores Reyes, a former employee of Prestress Manufacturing Corp., claimed he was wrongfully terminated. The Supreme Court's ruling clarifies how motions for reconsideration and relief from judgment impact the timelines for filing labor claims under Puerto Rican law.
Background
The dispute began when Javier Flores Reyes was hired by Prestress Manufacturing Corp. in 2014 as a Plant Manager. After being dismissed on August 3, 2017, he filed a complaint against the company on March 12, 2018, alleging unjust dismissal under Law No. 80 of May 30, 1976, and retaliation under Law No. 115 of December 20, 1991.
After several years and a period of inactivity on Flores Reyes's part, the First Instance Court dismissed his initial complaint on November 7, 2022. Following this dismissal, Flores Reyes filed a motion for reconsideration and relief from judgment on November 28, 2022. The court denied this motion on August 18, 2023. Subsequently, Flores Reyes filed a second complaint on February 15, 2024, which led to the current legal proceedings.
The Ruling
The Puerto Rico Supreme Court ruled that the expedited labor procedure under Law No. 2 of October 17, 1961, does not allow for motions for reconsideration. The court stated, "the summary procedure is incompatible with reconsideration motions" and clarified that simply filing a motion for relief does not interrupt the prescriptive terms unless the motion is granted.
Judge Erick V. Kolthoff Caraballo delivered the opinion, emphasizing that the mere act of filing a motion for relief does not suspend the timeline for filing a claim. Therefore, Flores Reyes's second complaint was deemed time-barred as it was filed over a year after the dismissal of the first complaint.
Impact
This ruling is significant for both employees and employers in Puerto Rico. It sets a clear precedent that motions for reconsideration are not permitted in expedited labor proceedings, which are designed for quick resolutions. The court's decision reinforces the importance of adhering to strict timelines for filing labor claims, thereby discouraging delays in the judicial process.
For employees, this ruling emphasizes the need for prompt action in labor disputes, as failure to comply with prescriptive periods can result in the loss of their claims. Employers, on the other hand, gain clarity on the procedural limitations that can protect them from prolonged litigation.
What's Next
The case can potentially be appealed, but the Supreme Court's ruling provides a strong precedent for future labor disputes in Puerto Rico. The court's decision may also influence ongoing and future cases involving similar claims under labor law.