In the case of San Juan Light & Transit Co. v. Requena, 1911, the U.S Supreme Court ruled in favor of Requena and upheld a judgment from lower courts that awarded damages to him for injuries sustained due to negligence by San Juan Light & Transit Company's employees. The company had argued that Puerto Rico's laws did not allow such claims because they were not specifically mentioned in its charter or franchise granted by Spain before cession to the United States. However, the court found this argument unconvincing as it was clear under general law principles applicable at both Spanish and American law that corporations could be held liable for torts committed by their employees within scope of employment even if there was no specific statutory provision allowing such suits.

In the dissenting opinion for San Juan Light & Transit Co. v. Requena, it was argued that the majority's decision to uphold a Puerto Rican law requiring street railway companies to provide free transportation for police and firemen in uniform violated principles of due process and equal protection under U.S. Constitution’s Fourteenth Amendment. The dissent contended that this law unfairly singled out one class of businesses (street railways) without providing any compensation or reciprocal benefits in return, thereby constituting an arbitrary exercise of legislative power which infringed upon property rights protected by the constitution. Furthermore, they disagreed with the majority's assertion that such laws were common practice elsewhere in America at the time; even if true, this would not automatically render them constitutional or justifiable on grounds other than public necessity or benefit directly related to their operation as utilities serving public needs.