Title
Shell Company of the Philippines, Ltd. vs. Firemen's Insurance Company of Newark
Case
G.R. No. L-8169
Decision Date
Jan 29, 1957
A car fell from a hydraulic lifter at a Shell-operated station, causing damage. Shell was held liable for negligence due to defective equipment and its agent's actions.

Case Summary (G.R. No. L-8169)

Applicable Law

The legal framework applicable to this case is rooted in the doctrine of agency and the notion of vicarious liability, illustrating how the acts of an agent (in this case, the station operator) can bind the principal (the Shell Company) under specific circumstances of negligence.

Background of the Incident

The facts reveal that Perlito Sison, acting on behalf of his father, took the Plymouth car to the Shell station for service. The agreement established that services would be rendered at a cost of P8.00. The car was placed on a hydraulic lifter operated by the station personnel, specifically by Porfirio de la Fuente. During the greasing process, the lifter was lowered to access a section of the car that could not be reached, resulting in the car falling and sustaining damages estimated at P1,651.38.

Actions Taken Post-Incident

Following the incident, the insurance companies, having compensated for the damages incurred to the vehicle, initiated a legal action alongside Salvador Sison against the Shell Company and de la Fuente to recover their loss. The initial ruling by the Court of First Instance of Manila dismissed the complaint, prompting an appeal to the Court of Appeals.

Court of Appeals Finding

The Court of Appeals subsequently reversed the lower court's ruling, emphasizing that Porfirio de la Fuente was acting as an agent of The Shell Company. The Court highlighted that De la Fuente occupied a position at the Shell station which conferred upon him duties controlled and directed by the Shell Company, substantiated by the exclusive right to sell Shell products and the company’s direct oversight and maintenance of the service station’s equipment.

Determination of Negligence

In assessing the negligence claim, the Court noted that the accident experienced by the vehicle was due to a mechanical failure associated with the hydraulic lift that had not been adequately checked prior to usage. Testimonies indicated that the initial operations of the hydraulic lifter were routine and that further diligence might have uncovered defects that contributed to the incident.

Liability of the Principal

The Court concluded that as the acts of De la Fuente and his employees were conducted within the scope of their employment, The Shell

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