The Puerto Rico Supreme Court dismissed an administrative appeal in *Mabel Reina Cubero v. Hon. Gildren S. Caro Pérez* (2025 TSPR 140) on December 18, 2025, after determining that the petitioner failed to comply with mandatory procedural requirements under Puerto Rico's Property Registration Law.
The case involved Mabel Reina Cubero, represented by attorney Juan J. Nolla Acosta, who sought to challenge a decision by Hon. Gildren S. Caro Pérez, the Property Registrar for the Aguadilla Section. The dispute centered on property registration matters, specifically the procedural requirements for filing administrative appeals before the Supreme Court.
Associate Justice Candelario López authored the court's opinion, which emphasized the importance of strict compliance with established procedural rules in property registration cases. The court held that Cubero failed to present a required recalification document as mandated by the Property Registration Law of the Commonwealth of Puerto Rico.
"We have the opportunity to clarify the procedural regulations established by our legal registry system for the purpose of presenting an administrative appeal before this Court," Justice López wrote. "Specifically, we are called to dismiss the appeal at hand, since we appreciate that the petitioner failed to comply with the requirements established by the Property Registration Law."
The court's decision focused heavily on the mandatory nature of the recalification requirement. Under Puerto Rico's property registration system, parties seeking to challenge registrar decisions through administrative appeals must first file a recalification document in accordance with established legal procedures.
The Supreme Court explained that dismissing the appeal was necessary to preserve the integrity of the property registration system and protect the qualifying function of Property Registrars throughout Puerto Rico. The court noted that accepting the appeal without proper compliance would ignore "the clear and unambiguous letter of the law" and would establish a harmful precedent that could undermine the registrars' essential role in property transactions.
Property registration law in Puerto Rico requires strict adherence to procedural requirements to ensure the reliability and accuracy of property records. The recalification process serves as an important safeguard, allowing registrars to review their initial decisions before cases proceed to higher courts. This system helps maintain the integrity of property records while providing an appropriate avenue for challenging registration decisions.
The case demonstrates the critical importance of procedural compliance in property law matters. Even substantive legal arguments cannot overcome fundamental procedural failures, particularly in the highly regulated area of property registration. The court's emphasis on protecting registrar functions reflects the specialized nature of property registration work and the need for clear procedural guidelines.
Justice López's opinion reinforced that courts cannot ignore statutory requirements, even when doing so might allow consideration of potentially meritorious claims. The decision reflects broader principles of administrative law, where procedural compliance often serves as a prerequisite to substantive review.
The dismissal in *Cubero* serves as a reminder to practitioners and property owners that administrative appeal processes require careful attention to procedural details. The recalification requirement is not merely a formality but an essential component of Puerto Rico's property registration system designed to promote efficiency and accuracy in property transactions.
For property lawyers practicing in Puerto Rico, the decision underscores the importance of thoroughly understanding and complying with all procedural requirements before filing administrative appeals. The court's firm stance on procedural compliance suggests that similar failures to follow established procedures will result in dismissals regardless of the underlying merits of the case.
The ruling also highlights the specialized nature of property registration law and the important role that registrars play in maintaining accurate property records. By protecting registrar functions from procedural shortcuts, the court reinforced the systematic approach required for effective property registration administration.
Moving forward, the *Cubero* decision will likely serve as precedent for similar procedural challenges in property registration cases. Property owners and their attorneys must ensure strict compliance with recalification requirements before pursuing administrative appeals to avoid similar dismissals.
The case reflects the Supreme Court's commitment to maintaining orderly administrative processes in property registration matters while ensuring that all parties understand and follow established legal procedures. This approach promotes predictability and reliability in Puerto Rico's property registration system, ultimately benefiting property owners and the broader real estate market.