The Puerto Rico Supreme Court exercised its disciplinary authority Dec. 3, 2025, ordering the immediate and indefinite suspension of notarial services for attorney José Manuel Pérez Pérez due to his failure to comply with court orders regarding notarial bond requirements.
The court issued a *per curiam* opinion in case TS-7,815, stating that it was exercising its disciplinary power to suspend a member of the legal profession from notarial practice for non-compliance with court requirements.
Pérez Pérez was admitted to practice law on Dec. 28, 1983, and took his oath as a notary on June 21, 1985. His legal troubles began when the Notarial Bond Fund of the Puerto Rico Bar Association filed an informational motion on Nov. 4, 2024, indicating that Pérez Pérez had outstanding notarial bond payments dating back to June 2016.
The Bar Association's Notarial Bond Fund, led by Executive Director José M. Montalvo Trías, requested cancellation of the bond provided by the attorney due to the extended period of non-payment spanning more than eight years.
The Supreme Court initially gave Pérez Pérez an opportunity to remedy the situation. On July 22, 2025, the court granted him a 30-day period to demonstrate that he had obtained notarial bond coverage for the period from June 2016 forward. When this deadline passed without the attorney's appearance or compliance, the court provided a final 10-day extension to fulfill the July 22, 2025 resolution.
According to the court's opinion, the attorney was warned about potential consequences for continued non-compliance during this final grace period. However, the document indicates that Pérez Pérez failed to meet even this extended deadline, prompting the court's disciplinary action.
Notarial bonds serve as financial protection for clients and the public against potential misconduct or errors by notaries in the performance of their duties. In Puerto Rico, as in other U.S. jurisdictions, notaries must maintain continuous bond coverage as a condition of their authorization to perform notarial acts.
The failure to maintain required notarial bond coverage represents a violation of professional obligations that can expose both notaries and their clients to financial risk. When notaries operate without proper bond coverage, they lack the financial protection mechanism designed to compensate parties who may suffer losses due to notarial errors or misconduct.
The Supreme Court's decision reflects its commitment to maintaining professional standards within Puerto Rico's legal community. By exercising its disciplinary authority, the court ensures that legal professionals comply with regulatory requirements designed to protect the public interest.
The immediate nature of the suspension means that Pérez Pérez must cease all notarial activities effective immediately. The indefinite duration indicates that restoration of his notarial privileges will depend on future compliance with court requirements, likely including payment of outstanding bond obligations and demonstration of current coverage.
This disciplinary action joins a broader pattern of professional regulation enforcement by Puerto Rico's highest court. The Supreme Court regularly monitors compliance with professional requirements and takes corrective action when attorneys fail to meet their obligations to clients and the public.
The case also highlights the administrative role of the Puerto Rico Bar Association's Notarial Bond Fund in monitoring compliance with bond requirements. The Fund's informational motion triggered the court's investigation and ultimately led to the disciplinary action against Pérez Pérez.
For practicing attorneys in Puerto Rico who also serve as notaries, this case serves as a reminder of the importance of maintaining current bond coverage. The significant gap between June 2016 and the 2024 motion suggests that compliance monitoring systems may identify violations that have persisted for extended periods.
The court's opinion was designated as 2025 TSPR 129 and will appear in volume 216 of the Puerto Rico Supreme Court Reports. The electronic distribution of the decision serves the public interest by providing transparency regarding disciplinary actions within the legal profession.
Moving forward, Pérez Pérez will need to address the underlying bond compliance issues to have any possibility of restoring his notarial authorization. The indefinite nature of the suspension means there is no automatic reinstatement date, and any restoration would require affirmative court action following demonstrated compliance with all requirements.
The case demonstrates the Puerto Rico Supreme Court's continued vigilance in maintaining professional standards and its willingness to take decisive disciplinary action when attorneys fail to meet their regulatory obligations, particularly those designed to protect public interests.