The Supreme Court of Puerto Rico issued a clarifying opinion on December 4, 2025, holding that non-resident bond requirements under Civil Procedure Rule 69.5 are incompatible with the summary labor proceedings established under Law No. 2 of October 17, 1961, as amended. The case, *Jack Javier Slim v. Royal Blue Hospitality, LLC H/N/C El Conquistador Resort-Puerto Rico*, addresses a procedural conflict that has significant implications for employment litigation in Puerto Rico.
The case arose from a labor dispute between Jack Javier Slim and Royal Blue Hospitality, LLC, which operates as El Conquistador Resort-Puerto Rico. Royal Blue Hospitality served as the petitioner in the certiorari proceeding, while Slim was the respondent. The case was assigned number CC-2025-0077 and decided by Associate Justice Rivera Pérez.
Attorney José R. Negrón Fernández represented Royal Blue Hospitality, while Luis F. Del Valle Emmanuelli served as counsel for Slim. The legal matter centered on employment law and specifically addressed whether Civil Procedure Rule 69.5's non-resident bond requirements apply to summary labor proceedings.
Law No. 2 of 1961, known as the Summary Procedure Law for Labor Claims, was enacted as a procedural mechanism for the rapid disposition and adjudication of labor claims filed by employees against their employers. The court emphasized that this summary procedure was strengthened as an expedited judicial mechanism to resolve labor claims by limiting the use and application of Civil Procedure Rules.
Section 3 of Law No. 2, codified at 32 LPRA section 3120, specifically restricts the application of civil procedure rules to ensure the summary nature of labor proceedings is preserved. This legislative framework was designed to provide employees with a streamlined process for pursuing workplace-related claims without the procedural complexities that might delay resolution.
Civil Procedure Rule 69.5, codified at 32 LPRA Appendix V, typically requires non-resident parties to post bonds in civil litigation. However, the Supreme Court of Puerto Rico determined that this bond requirement conflicts with the expedited nature of summary labor proceedings intended by the legislature.
The court's opinion, written by Associate Justice Rivera Pérez, serves as the final interpretative authority on the applicability of Civil Procedure Rule 69.5 to summary labor proceedings. The decision clarifies a procedural conflict that had created uncertainty in employment litigation involving non-resident parties.
The ruling has particular significance for Puerto Rico's hospitality industry, which employs both residents and non-residents. El Conquistador Resort, a major tourism destination on the island, represents the type of employer that could be affected by this procedural clarification. The decision ensures that non-resident employees or employers cannot be subjected to additional bond requirements that would delay or complicate labor dispute resolution.
The Supreme Court of Puerto Rico's decision reinforces the legislative intent behind Law No. 2 of 1961, which was to create an accessible and efficient forum for resolving employment disputes. By limiting the application of general civil procedure rules, the legislature sought to prevent procedural obstacles from interfering with workers' ability to pursue legitimate claims against their employers.
This ruling also reflects broader policy considerations regarding access to justice in employment matters. Summary labor proceedings are designed to level the playing field between employees and employers, who often have vastly different resources and legal representation. Imposing additional bond requirements on non-resident parties could create barriers to accessing these streamlined proceedings.
The decision is catalogued as 2025 TSPR 133 and will appear in volume 216 of the Puerto Rico Supreme Court Reports. The opinion serves as binding precedent for all Puerto Rico courts handling similar procedural questions in labor cases.
For practitioners representing parties in Puerto Rico labor disputes, this decision provides important guidance on procedural requirements. Attorneys handling cases involving non-resident parties can now rely on clear authority that Civil Procedure Rule 69.5 bond requirements do not apply to summary labor proceedings.
The ruling also has implications for case strategy and litigation costs in employment disputes. Without the burden of posting non-resident bonds, parties can focus on the substantive merits of their labor claims rather than procedural obstacles.
Looking ahead, this decision may influence how other procedural rules interact with Puerto Rico's summary labor proceedings. The court's emphasis on preserving the expedited nature of these proceedings suggests that other civil procedure requirements that could delay resolution may face similar scrutiny.
The Supreme Court of Puerto Rico's ruling in *Slim v. Royal Blue Hospitality* clarifies an important procedural question while reinforcing the legislative policy of providing accessible forums for resolving employment disputes. The decision ensures that summary labor proceedings remain truly summary in nature, free from procedural requirements that could undermine their effectiveness as a remedy for workplace disputes.