RIOP Corporation v. José González Laabes

RIOP Corporation v. José González Laabes

Citation: TA2025AP00332, Tribunal de Apelaciones de Puerto Rico, Panel Especial (Nov. 6, 2025)

Relevant Facts

  • On April 18, 2017, the parties entered into a lease agreement with purchase option for a commercial property of approximately 13,000 square feet in Rincón, Puerto Rico, plus an adjacent solar (lot) including a mechanical workshop area.

  • RIOP was granted the option to purchase within five years at $800,000.

  • In December 2021, RIOP notified González Laabes of its intent to exercise the purchase option.

  • During finalization, González Laabes refused to include the adjacent solar (mechanical workshop area) in the deed of sale.

  • In April 2023 the trial court rendered judgment ordering González Laabes to complete the sale, including the adjacent solar, and to segregate it; that judgment became final after the Supreme Court denied certiorari.

  • A visual inspection determined the solar to segregate comprised approximately 600–620 square meters, including the mechanical workshop and its parking area.

  • González Laabes sought review of the trial court’s July 18, 2025 enforcement resolution, alleging it erred in determining the scope of the solar and showed bias toward RIOP.

Contract interpretation of the adjacent solar included in the purchase option; specific performance and property segregation requirements; and whether the trial court’s factual findings were supported by evidence.

Positions of the Parties

González Laabes: Alleged multiple errors including adjudicating without evidence, ordering segregation of land never described in the contract or claimed, and showing bias toward RIOP.

RIOP: The final judgment required segregation of a lot of about 800 square meters covering the mechanical workshop and its parking; limiting it to the workshop alone would leave the lot without access.

Decision of the Court

AFFIRMED. The trial court’s determination that the area to be segregated comprises approximately 600–620 square meters was upheld.

Reasons for the Decision

  • The contract explicitly included the adjacent solar of the mechanical workshop area.

  • The trial court’s factual findings were consistent with evidence presented at trial and confirmed during the visual inspection.

  • No indication of partiality or error by the trial court.

  • The mechanical workshop and its parking area are a unified space with sole access through the front parking.

  • The court also relied on González Laabes’s own sworn testimony that the lot measured about 800 square meters, RIOP’s long possession of the area, and the bank appraisal that included the parking.

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