Africa v. Caltex (Phil.), Inc.

Summary

Property owners sued Caltex and station operator Boquiren for damages when fire spread from gasoline station to neighboring houses. Lower courts dismissed for failure to prove negligence and inadmissibility of investigative reports. Supreme Court reversed, applying res ipsa loquitur doctrine since gasoline operations require extreme care and fire occurred without explanation from defendants who had exclusive control. Court found Boquiren was Caltex's agent based on extensive control provisions in their agreement, making both liable. Awarded damages totaling P19,005.80 with interest and costs. Case establishes important precedents for tort liability in hazardous operations and agency relationships in Philippine jurisprudence.