31 P.R. Laws Ann. § 3343

Section 3343 bars relitigation when the prior and later suits have perfect identity of the things, causes, and litigants in their litigating capacity, including sufficient identity of interest and the same underlying object and cause.

Fed. Sec. L. Rep. P 92,024 Futura Development Corporation v. Centex Corporation · filed 1985-04-30

P.R. Laws Ann. tit. 31, § 3343, Puerto Rico’s res judicata statute provides: ... In order that the presumption of the res adjudicata may be valid in another suit, it is necessary that, between the case decided by the sentence and that in which the same is invoked, there be the most perfect identity between the things, causes, and persons of the litigants, and their capacity as such. ... Identity of parties and interest is required so that a party’s rights and obligations will not be determined without their knowledge or an opportunity for participation. ... Accordingly, we find that the parties in the commonwealth court action have sufficient identity of interest to be viewed as identical parties within the parameters of P.R. Laws Ann. tit. 31, § 3343. ... We, therefore, find an identity of “things.” ... We think that the facts alleged compel the conclusion that the requirements of § 3343 of res judicata have been met in this ease.

Section 3343 does not require a literal identity of the parties for res judicata; preclusion may apply when the real parties in interest are the same.

Arecibo Radio Corporation v. Commonwealth of Puerto Rico · filed 1987-08-03

Although the statute requires “perfect identity” between the actions, courts have not given this term a literal interpretation. Res judicata applies even though the parties differ, as long as the real parties in interest are the same.

Section 3343 requires identity of the things, causes, and litigants for res judicata, but “perfect identity” is not interpreted literally.

Rocca v. Royal Bank of Canada, P.R. Inc. · filed 1989-09-15

Although the statute requires “perfect identity” between the actions, courts have not given this term a literal interpretation.

Section 3343 treats litigants as identical for res judicata through legal representation or joint binding only when a single actor played a meaningful role in both suits.

Mercedes Montalvo-Huertas, Etc. v. Hector Rivera-Cruz, Etc. · filed 1989-09-20

Under Commonwealth law, application of the quoted language requires that some single actor play a meaningful role in both the earlier and later suits, whether or not behind the scenes.

Section 3343 requires the most perfect identity of the things, causes, parties, and their legal capacities for res judicata to apply between a prior case and the current case.

De Arellano v. American Airlines, Inc. · filed 1997-02-27

P.R.Laws Ann. tit. 31, § 3343 establishes that for res judicata to apply, there must be present the most perfect identity between the things, causes and persons of the litigants and their capacity as such between the prior case and the current case.

Section 3343 requires the prior and subsequent suits to have the most perfect identity of things, causes, litigants, and the litigants’ capacity for res judicata to apply.

Cortes v. Intermedics, Inc. · filed 1999-08-25

“In order that the presumption of res judicata may be valid in another suit, it is necessary that, between the case decided by the sentence and that in which the same is invoked, there be the most perfect identity between the things, causes, and persons of the litigants, and their capacity as such.”

Section 3343 requires res judicata to be supported by the most perfect identity of the things, causes, and litigants in the two cases.

Marcano Arroyo v. K-Mart, Inc. · filed 1999-12-22

In addition to the requirements of a final and unappealable adjudication on the merits by a court with jurisdiction, the Puerto Rico Civil Code provides that for res judicata to apply between two cases there must be “the most perfect identity between the things, causes, and persons of the litigants.” P.R. Laws Ann. tit. 31, § 3343 (1991); ... Here there is complete identity of the persons: the parties are the same in both cases. ... Thus, there is also an identity of things between the two cases.

Section 3343 requires identity of things, causes, and litigants for res judicata, but its identity-of-parties requirement may be applied nonliterally to legal representatives, jointly bound parties, or parties in privity.

Toro v. University of Puerto Rico · filed 2001-12-28

The preclusion statute provides that there is identity of parties whenever “the litigants of the second suit are legal representatives of those who litigated in the preceding suit, or when they are jointly bound with them or by the relations established by the indivisibility of prestations among those having a right to demand them, or the obligation to satisfy the same.” P.R. Laws Ann. tit. 31, § 3343. Although Puerto Rico’s mutuality requirement is strictly worded, on a number of occasions the Puerto Rico courts have not read this requirement literally.

Section 3343 makes res judicata applicable only when there is the most perfect identity among the things, causes, parties, and their capacity as litigants.

MORALES v. Municipality of San Juan · filed 2008-08-13

Under Puerto Rico law, res judicata applies where there exists “the most perfect identity between the things, causes and persons of the litigants, and their capacity as such.” P.R. Laws Ann. tit. 31, § 3343. ... The passenger-plaintiffs never served Montañez in the Puerto Rico court litigation. ... Having never received or waived service of process, Montañez did not participate in the Puerto Rico court litigation or the settlement compromise. Under such circumstances, the court concludes that neither claim preclusion nor issue preclusion bars Montañez from asserting her claim against the Municipality in this forum.

Section 3343 treats res judicata as encompassing both claim preclusion and issue preclusion and requires identity of parties, including legally sufficient privity; shared interests alone do not establish it.

Coors Brewing Co. v. Méndez-Torres · filed 2009-03-30

Although this statute speaks of "res adjudicata," it encompasses both the doctrine of res judicata (i.e., claim preclusion) and the doctrine of collateral estoppel (i.e., issue preclusion), albeit with slightly different requirements for each. ... This is a privity requirement, and the Puerto Rico Supreme Court has taken a "pragmatic stand" on its construction. ... Thus, on this factual record, it is proper to reach the same result as in Pérez-Guzmán: in the absence of evidence that Coors controlled the U.S. Brewers (P.R.) action, the similarity of interests between Coors and the USBA is inadequate to establish the representation or "indivisibility of prestations" required to find sufficient identity of parties under Puerto Rico law.

Section 3343 requires the most perfect identity between the things, causes, and persons of the litigants for Puerto Rico issue and claim preclusion.

Berríos-Romero v. Estado Libre Asociado De Puerto Rico · filed 2011-04-27

Under Puerto Rico issue and claim preclusion law, P.R. Laws Ann. tit. 31, § 3343, there must be "the most perfect identity between the things, causes, and persons of the litigants."

Section 3343 codifies Puerto Rico res judicata by requiring perfect identity of the things, causes, and parties and their capacities between the prior and current cases, encompassing claim preclusion.

Castillo Condominium Ass'n v. United States Department of Housing & Urban Development · filed 2016-05-02

In Puerto Rico, the doctrine of res judicata is codified by statute. Under that statute, "it is necessary that, between the case decided by the sentence and that in which the same is invoked, there be the most perfect identity between the things, causes, and persons of the litigants, and their capacity as such." P.R. Laws Ann. tit. 31, § 3343. This definition encompasses, inter alia, the doctrine of claim preclusion.

Section 3343 bars relitigation of a claim only when there is the required identity of the things, causes, persons, and their legal capacities between the prior and later proceedings.

Garcia-Melendez v. Gonzalez · filed 2017-01-05

This doctrine applies only if “there [is] the most perfect identity between the things, causes, and persons of the litigants, and their capacity as such” in the case decided by the judgement “and that in which the same is invoked.” P.R. Laws Ann. tit. 31, § 3343.

Former § 3343 required perfect identity of the parties and cause of action for res judicata, but it was repealed and was not operative when the district court relied on it.

Cangrejeros de Santurce Baseball Club, LLC v. Liga de Beisbol Profesional de Puerto Rico, Inc. · filed 2025-07-21

In addition, it is not evident that the District Court did correctly apply § 3343. As the plaintiffs point out, neither the parties nor the cause of action were identical between the prior suit and this suit, and § 3343 appears to require "perfect identity" in those elements across the two cases. P.R. Laws Ann. tit. 31, § 3343. In such circumstances, we see no reason to let the District Court's ruling stand based on a statute that it is agreed by both parties was not operative at the time that the District Court relied on it and that the District Court appears to have misapplied in any event. We thus cannot affirm the District Court's ruling insofar as it rests on § 3343.

Section 3343 limits res judicata to cases involving the most perfect identity of the things, causes, and litigating parties.

Catullo v. Metzner · filed 1987-12-02

The Civil Code limits the presumption of res judicata to situations in which “between the case decided by the sentence and that in which the same is invoked, there be the most perfect identity between the things, causes, and persons of the liti-gants_” P.R.Laws Ann. tit. 31, § 3343 (1968).

Section 3343 requires identity of the things, causes, and litigating persons (and their capacity) for res judicata, but “perfect identity” is not interpreted literally.

Oficinas Medicas, Inc. v. de Melecio · filed 1999-03-12

Although the statute above mentioned is clear in its language, the courts have not felt bound to interpret “perfect identity” literally.

Section 3343 requires identity of things, causes, and parties for res judicata; claims arising from the same lease agreements and claims against parties in privity can satisfy that requirement.

Paniagua v. CORPORACION DE FOMENTO RECREATIVO · filed 1997-09-30

In order to apply the doctrine of res judicata in a subsequent suit, the Civil Code of Puerto Rico provides that “it is necessary that, between the case decided by the sentence and that in which the same is invoked, there be the most perfect identity between the things, causes, and persons of the litigants, and their capacity as -such.” P.R. Laws Ann. tit. 31, § 3343. ... The present action fulfills all the requirements for the application of the doctrine of res judicata.

Section 3343’s requirement of perfect identity is not literal; nominal differences between parties do not prevent a prior judgment from having preclusive effect.

Perez-Guzman v. Commonwealth of PR · filed 2003-10-09

We know that the requirement of "perfect identity" cannot be taken literally; mere nominal differences will not undermine the preclusive effect of an earlier judgment.

Section 3343’s identity-of-parties requirement can be satisfied by privity; it does not require the parties to be literally identical.

Cruz-Berrios v. Rosario · filed 2010-12-16

Yet the Puerto Rico res judicata statute's "perfect identity of parties" clause does not demand a literal identity; it operates, rather, as a privity requirement.

Section 3343 requires perfect identity of things for res judicata; a judgment addressing only equitable relief does not bar a damages claim dismissed without prejudice.

Gonzalez v. Axa Equitable Life Insurance · filed 2008-08-11

Since the state court did not notice the action for damages, it never addressed and adjudicated the issues needed for its determination. When confronted with the oversight, the trial court simply dismissed the damages action without prejudice. Therefore, there is no perfect identity of “things,” and the third requisite of adjudication “on the merits” is not met. Hence, this suit is not barred by res judicata.

Section 3343 requires a final judgment on the merits and identity of thing, cause, and parties or their privies for claim preclusion.

Dorpan, S.L. v. Hotel Melia, Inc. · filed 2012-03-31

A party asserting claim preclusion under Puerto Rico law must demonstrate: “(i) there exists a prior judgment on the merits that is final and unappealable; (ii) the prior and current actions share a perfect identity of both thing and cause; and (iii) the prior and current actions share a perfect identity of the parties and the capacities in which they acted.” ... The court finds elements (i) and (iii) to be lacking in this case because the judgment was not on the merits and the parties are not the same between the 1978 litigation and the present case. Therefore, claim preclusion does not bar DSD’s claims in this case.

Section 3343’s identity-of-parties requirement can be satisfied by privity when an added party’s liability depends on a party to the earlier suit.

Camacho-López v. Del Capitolio · filed 2015-09-04

In this case, both the Commonwealth and the fictitious insurers possess sufficient privity with co-defendants Superintendencia and Vázquez, who were also co-defendants in the Commonwealth case, to be viewed as identical parties under Puerto Rico law. After all, any liability of the Commonwealth, under respondent superior, and of the insurers, under the insurance contract, will track and be fully contingent upon the liability, if any, of Superintendencia and Vázquez.

Section 3343 requires identity of the things, causes, and litigants for preclusion, and a claim arising from the same operative facts is not rendered a different cause merely because it is pursued under a different legal theory.

Muñiz Cortes v. Intermedics, Inc. · filed 2000-10-03

Appellants also take issue with the district court's conclusion that there existed "perfect identity between the things, causes, and persons of the litigants" as required under the Puerto Rico law of preclusion. See P.R. Laws Ann. tit. 31, § 3343. ... The fact that appellants advanced different legal theories does not undermine the identity of causes, because the commonwealth law claim presented in the superior court arose from the pacemaker failure, just as did the claims later presented to the federal district court. ... A claim is precluded not only if it was actually raised in a previous suit, but if it could have been raised.

Section 3343 makes res judicata applicable when there is the most perfect identity of the things, causes, and persons of the litigants and their capacity, and Puerto Rico courts interpret it to allow issue preclusion even when the causes are not identical.

Morón-Barradas v. Department of Education · filed 2007-05-24

Under Puerto Rico law, res judicata applies when there is "the most perfect identity between the things, causes, and persons of the litigants, and their capacity as such." P.R. Laws Ann. tit. 31, § 3343. Puerto Rico courts have interpreted the statute to permit issue preclusion, or collateral estoppel, as well, even when identity of causes is lacking.

Section 3343 applies to both res judicata and collateral estoppel.

Nunez-Colon v. Toledo-Davila · filed 2011-05-26

Much of the case law addressing the public policy exception speaks in terms of res judicata. The relevant Puerto Rico statute, P.R. Laws Ann. tit. 31, § 3343, applies to both res judicata and collateral estoppel and therefore we use the terms interchangeably. See Puerto Ricans for P.R. Party v. Dalmau, 544 F.3d 58, 69 (1st Cir. 2008).

Section 3343 requires a prior final judgment, perfect identity of thing or cause, and perfect identity of parties and their capacities for res judicata to apply under Puerto Rico law.

Grajales v. Puerto Rico Ports Authority · filed 2019-04-29

Thus, to demonstrate that the judgment of the Court of First Instance has res judicata effect here, the PRPA "must establish three elements: (i) the existence of a prior judgment on the merits that is 'final and unappealable'; (ii) a perfect identity of thing or cause between both actions; and (iii) a perfect identity of the parties and the capacities in which they acted."

Section 3343 makes a later suit subject to Puerto Rico res judicata when there is a final judgment, perfect identity of the thing or cause, and perfect identity of the parties and their capacities.

Cangrejeros de Santurce Baseball Club, LLC v. Liga de Beisbol Profesional de Puerto Rico, Inc. · filed 2023-06-27

The doctrine of res judicata in Puerto Rico is inscribed in the Civil Code: In order that the presumption of res adjudicata may be valid in another suit, it is necessary that, between the case decided by the sentence and that in which the same is invoked, there be the most perfect identity between the things, causes, and persons of the litigants, and their capacity as such. P.R. Laws Ann. tit. 31, § 3343. Thus, “a party asserting a res judicata defense under Puerto Rico law must establish three elements: (i) the existence of a prior judgment on the merits that is ‘final and unappealable’; (ii) a perfect identity of thing or cause between both actions; and (iii) a perfect identity of the parties and the capacities in which they acted.”

Section 3343 codifies Puerto Rico's res judicata law, encompassing both claim preclusion and issue preclusion, with different requirements for each.

Garcia-Monagas v. de Arellano · filed 2012-03-16

Puerto Rico's law of res judicata is codified at P.R. Laws Ann. tit. 31, § 3343,6 which has been interpreted as encompassing both claim preclusion and issue preclusion (issue preclusion is also sometimes referred to as collateral estoppel), "albeit with slightly different requirements for each."

Section 3343 encompasses both claim preclusion and issue preclusion, with somewhat different requirements for each.

R.G. Financial Corp. v. Vergara-Nuñez · filed 2006-04-21

Although this statute speaks of "res adjudicata," it encompasses both the doctrine of res judicata (i.e., claim preclusion) and the doctrine of collateral estoppel (i.e., issue preclusion), albeit with slightly different requirements for each.

Section 3343 requires identity of things, causes, and parties for res judicata, and bars only claims that were or could have been litigated in the earlier action.

Garcia v. Salas · filed 1988-06-08

Thus, in order for the res judicata defense to be effective, there must be identity between “things”, “causes” and parties. ... If these three conditions are met, a judgment rendered constitutes an impediment in a subsequent action as to claims that were or could have been litigated in the former action. ... These three identities are present here. ... However, the commerce clause claim before us was not litigated in the local forae. And we believe it could not have been adjudicated there because, under Puerto Rican law, as exposed by the Puerto Rico Supreme Court, the clause is inapplicable to the Island. Thus, the res judicata defense has no merit.

Section 3343 applies to collateral estoppel as well as res judicata.

Zayas v. Rico · filed 2005-11-30

Although this provision refers to res judicata, it has also been applied for purposes of collateral estoppel.

Section 3343 encompasses collateral estoppel as well as res judicata.

Cruz-Berrios v. Gonzalez-Rosario · filed 2008-09-18

Although this provision only refers to res judicata, it encompasses as well collateral estoppel, also termed issue preclusion.

Section 3343 requires a prior final judgment on the merits and identity of claims and parties for res judicata to bar a later suit.

Rivera v. Puerto Rico Electric Power Authority · filed 2014-03-14

The elements of this test are: 1) a final judgment on the merits in an earlier suit; 2) perfect identity between the causes of action asserted in the earlier and later suits; and 3) perfect identity between the parties in the two suits. ... Accordingly, the Court finds that Plaintiffs’ claims are not barred under the doctrine of res judicata, emphasizing that the record simply does not show that a final judgment on the merits was ever entered in the state court proceedings and that the parties in both causes of action were “identical.”

Section 3343's res judicata provision also permits issue preclusion.

Puerto Ricans for Puerto Rico Party v. Dalmau · filed 2008-10-06

Although the statute uses the phrase "res judicata," that is, claim preclusion, it also permits issue preclusion.

Section 3343 required claim preclusion to involve a final, unappealable merits judgment, perfect identity of the thing and cause, and perfect identity of the parties and their capacities.

Rivera-Rosario v. LSREF2 Island Holdings, Ltd., Inc. · filed 2023-08-17

Under Puerto Rico law as it existed when Rivera commenced the 2020 litigation,1 a party asserting claim preclusion "must establish three elements: '(i) there exists a prior judgment on the merits that is "final and unappealable"; (ii) the prior and current actions share a perfect identity of both "thing" and "cause"; and (iii) the prior and current actions share a perfect identity of the parties and the capacities in which they acted.'" Medina-Padilla, 815 F.3d at 86 (quoting García-Monagas v. De Arrellano, 674 F.3d 45, 51 (1st Cir. 2012)); see also P.R. Laws Ann. tit. 31, § 3343 (repealed 2020); Lausell Marxuach v. Diaz de Yanez, 3 P.R. Offic. Trans. 742, 745 (1975).

Section 3343 encompasses both claim preclusion (res judicata) and issue preclusion (collateral estoppel), with different requirements for each.

Rivera-Feliciano v. State Insurance Fund Corp. · filed 2009-09-03

“Although this statute speaks of ‘res adjudicata,’ it encompasses both the doctrine of res judicata (i.e., claim preclusion) and the doctrine of collateral estoppel (i.e., issue preclusion), albeit with slightly different requirements for each.”

Section 3343 permits issue preclusion without strict identity of parties or causes of action when an issue was fully litigated and resolved in a final judgment.

Diaz-Baez v. Alicea-Vasallo · filed 2021-12-23

The arguments misconstrue the doctrine of issue preclusion under Puerto Rico law, which requires neither strict identity of parties nor causes of action.