P.R. Supreme Court determines that mere exhaustion of 12-month reserve period under the CSIF may not be just cause for terminating an employee who relapses and requires additional medical treatment.
- scmplex
- Jul 14
- 2 min read
SCMP Breaking News - Labor & Employment
Year 10, Vol. 3 - July 12, 2025
On June 26, 2025, the Puerto Rico Supreme issued its ruling in the case of Méndez Ruiz v. Techno Plastics Industries, Inc., 2025 TSPR 68, 216 DPR ___ (2025). The case involved Silmarie Méndez Ruiz (“Méndez”), who was terminated by her employer after suffering a relapse which made her return the Corporation of State Insurance Fund (“CSIF”) to receive additional medical treatment after she had exhausted the one-year mandatory employment reserve period. The Supreme Court of Puerto Rico ruled that returning to the CSIF to receive additional medical treatment after the one-year employment reserve had elapsed, by itself, does not constitute just cause for dismissal under Puerto Rico Law No. 80 of May 30, 1976 (“Law 80-1976”).
In this case, Méndez (the employee) had suffered an occupational disability in 2018 that required her to receive treatment at the CSIF, which ordered her to rest. However, before the twelve (12) month employment reserve period expired, Méndez requested to be reinstated to her position. Accordingly, her employer reinstated her to her position, where she worked uninterruptedly for nearly two (2) years, prior to suffering a relapse from the same condition at which time she was ordered to rest by the CSIF. Thereafter, her employer, Techno Plastic Industries (“Techno Plastics”) terminated her employment because she was unable to work and the twelve (12) month reserve period had elapsed.
The Supreme Court of Puerto Rico ruled that the dismissal of the employee was not justified by the mere fact that Méndez returned to the CSIF to receive additional medical treatment after the original 12-month employment reserve period had elapsed. The Court emphasized the need to examine the totality of the circumstances and that, in this particular case, it was significant that Méndez had been reinstated and had worked for nearly two (2) years after she was originally ordered to rest by the CSIF prior to seeking additional medical treatment at the CSIF.
What does this decision mean for employers?
This ruling by the Supreme Court of Puerto Rico makes clear that employers must carefully examine the circumstances of each particular case when determining whether to dismiss an employee who suffers a relapse from an occupational medical condition that previously required CSIF-ordered rest and treatment, as the mere exhaustion of the 12 month reserve period by itself may not be considered just cause for dismissal.
What should employers do?
Train management and human resources personnel regarding this decision and its implications.
Should you require further advice or assistance in relation to this matter, please contact us at (787) 945-0380.
Because of the general nature of this newsletter, nothing herein should be construed as legal advice or a legal opinion. SCMP Breaking News and all its content is property of Silva-Cofresí, Manzano & Padró, LLC
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