Justo Valle v. American International Insurance Company & Gloria Dinorah Díaz
Puerto Rico Supreme Court
108 D.P.R. 692 (1979)
- Written by Whitney Waldenberg, JD
Facts
[Ed.’s note: This case is significant because it overruled decades of Puerto Rican caselaw that analyzed local cases under United States legal methods, including the common law. The opinion established that cases decided under Puerto Rican law (as opposed to federal law) by Puerto Rican courts must be based on Puerto Rico’s civil law, not the common law.] Justo Valle (plaintiff) and Gloria Dinorah Díaz (defendant) were drivers of two separate cars, both waiting in line to make a left turn. The line was five cars long; Valle was the driver of the second car, and Díaz was the driver of the third car. A sixth car collided with a line of cars, causing a chain reaction, forcing Díaz’s car into Valle’s car. Valle sued Díaz for damages. The trial court determined that Díaz’s car was sitting too close to Valle’s car and, therefore, her conduct was the proximate cause of the collision with Valle. In so ruling, the trial court held Díaz liable to Valle for mental suffering and bodily injuries, as well as damage to his vehicle and for the mental suffering of Valle’s wife. Díaz appealed.
Rule of Law
Issue
Holding and Reasoning (Trías Monge, C.J.)
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