On 1 June 1994, the M/T Mantinia ran aground off the south coast of Puerto Rico. The M/T Mantinia was registered under the laws of Greece and owned by Metro Freighting Corp which also had its principal offices in Greece. The salvage services were provided by Smit Americas Inc (the plaintiff) on 3 June 1994. The plaintiff brought a salvage award claim on 7 December 1995, which was 18 months after the event giving rise to the litigation. The plaintiff was a US company incorporated in Delaware.

Metro Freighting Corp and its insurers (the defendants) moved to dismiss the claim on the ground that the claim was time-barred. The defendants argued that the one-year statute of limitation provided in art 948 of the Puerto Rico Commerce Code should apply. On the contrary, the plaintiff argued that the two-year statute of limitation provided in art 10 of the Convention for the Unification of Certain Rules of Law Relating to Assistance and Salvage at Sea 1910 (Salvage Convention 1910) should apply. The plaintiff contended that Puerto Rico possesses no foreign relations power, but is linked to the United States and hence is a part of its political system compatible with its federal structure. Thus, Puerto Rico cannot enact legislation in contravention of a treaty between the United States and other sovereign nations.

Held: Motion denied.

Puerto Rico's authority over its territorial waters is not absolute but must yield to express Congressional intent. Furthermore, this geographical area is also subject to federal legislative measures taken under the constitutional powers of the United States. The Congress of the United States in the enactment of Public Law No 600 does not intend to vest Puerto Rico with the power to alter or affect a US treaty with other nations, despite the fact that the provisions of the Salvage Convention 1910 are not expressly made applicable to Puerto Rico. Thus, the limitation period applicable to a salvage claim is the two-year term provided for in the Salvage Convention 1910.