Re: Tortious Interference Claim Against Non-Contracting Parties
After a group of siblings agreed to partition their father’s estate, one brother failed to comply, allegedly due to his wife’s opposition. This case evaluates whether a spouse’s verbal objections can amount to tortious interference with the other spouse’s contractual obligations. Upon careful analysis, the Puerto Rico Supreme Court (“Supreme Court”) ultimately held that mere expressions of disagreement do not amount to actionable interference under the doctrine of tortious interference, especially in the context of marital relations.
Enrique Batista-Martínez (“Enrique Batista”) passed away in 2010. He left behind a will in which he declared his children, including Elena Batista-Valentín (“Elena Batista”) and José Enrique Batista-Valentín (“José Batista”), as universal heirs. The siblings executed an agreement of heirs to partition the estate and sign the necessary deeds of segregation. José Batista, however, later refused to sign the deeds required by the agreement.
Soon after, Elena Batista filed suit against her brother for breach of contract and damages. Elena Batista claimed that José Batista had refused to sign the deeds because his wife, Damaris Reyes-Montañez (“Damaris Reyes”), opposed the agreement and intentionally interfered with his contractual obligations. José Batista died during litigation, and his estate, including Damaris Reyes, was substituted as a party. Damaris Reyes contended that her husband was gravely ill and incapacitated when he signed the agreement, and that her objections merely reflected her role as a concerned spouse rather than any intentional interference.
In 2016, the Court of First Instance (“CFI”) entered partial judgment for breach of contract and tortious interference. The Court of Appeals reversed, citing factual disputes regarding José Batista’s capacity to consent. After remand, Damaris Reyes sought summary judgment before the CFI, arguing that her objections to the execution of the deeds did not amount to tortious interference for the reasons previously discussed.
The CFI granted summary judgment in 2022 and dismissed the tortious interference claim with prejudice. The CFI did not make specific findings of fact or conclusions of law. After a series of procedural incidents, Elena Batista appealed, alleging that the CFI erred in dismissing the claim without establishing findings of fact or conclusions of law. The Court of Appeals reversed the CFI’s decision once again, holding that genuine issues of material fact precluded summary judgment. Damaris Reyes then sought certiorari before the Puerto Rico Supreme Court, who granted review.
The Supreme Court reviewed whether the CFI properly disposed of the tortious interference claim through summary judgment despite alleged subjective elements of intent, and whether a non-contracting spouse’s verbal objections can constitute tortious interference with the contractual obligations of the other spouse.
The Supreme Court reversed the Court of Appeals’ decision and reinstated the CFI’s summary judgment. The Court concluded that the CFI acted properly in disposing of the case summarily because the evidence was insufficient to establish the elements of tortious interference. A spouse’s objections or verbal expressions of disagreement do not, by themselves, constitute culpable interference with the other spouse’s contractual duties.
Substantively, the Court revisited the doctrine of tortious interference, which requires proof of a) a valid contract with which the third-party interferes; b) fault or intent by a third party; c) resulting damage; and c) a causal link between the interference and the damage.
While the agreement of the heirs constituted a valid contract, the record contained no evidence that Damaris Reyes acted intentionally or caused the non-performance. The Supreme Court stated that mere expressions of disagreement, like stating that she would not allow or take her husband to sign the deeds, did not amount to actionable interference. Moreover, she was not a party to the contract and therefore bore no legal obligation to ensure her husband’s compliance.
The Supreme Court clarified that the obligations arising from a contract bind only its signatories and their heirs. Imposing liability on a spouse merely for expressing disapproval would unjustly extend contractual duties to non-parties and conflict with fundamental principles of contractual autonomy.
CONCLUSION
The Supreme Court concluded that the evidence failed to establish a cause of action for tortious interference under Article 1802 of the 1930 Civil Code. The CFI correctly granted summary judgment, as no material facts were in dispute and the respondent’s claim rested solely on unsubstantiated assertions of verbal opposition. Accordingly, the Court of Appeals’ decision was reversed, and the CFI’s summary judgment was reinstated.
Justice Estrella-Martínez dissented, stating that genuine factual disputes existed, particularly regarding intent and the degree of control exercised by Damaris Reyes over her ill husband, warranting a full trial. Justice Colón-Pérez also dissented on the grounds that the Court lacked jurisdiction due to untimely notification of the petition of certiorari.
Author: Zulinnette Pinzón-Rosario
This article was originally published in From the Bar, Spring 2026, Issue No. 68 — a publication of the Federal Bar Association, Hon. Raymond L. Acosta Puerto Rico Chapter. Reproduced with attribution for informational purposes.
