## Facts

- Enrique Castillo de Jesús, an employee of a company other than the defendant warehouse, went in a van to pick up merchandise from Almacén Ramón Rosa Delgado, Inc.
- After the initial load, Castillo was told to obtain two additional wooden crates of bottled soda water.
- A warehouse employee transported the two crates on a two-wheeled hand truck about 40–50 feet to the van; the crates were partially open at the top.
- As Castillo lifted the first crate from the hand truck to place it in the van, a bottle exploded and struck his right eye, causing serious injury.
- The warehouse stored similar bottled merchandise stacked about five to six feet high in a non-air-conditioned interior at ambient temperature.
- The State Insurance Fund’s administrator sued on behalf of Castillo and for reimbursement of benefits paid, alleging negligence under Civil Code article 1802 against the warehouse and its liability insurer.

## Issues

1. Whether Puerto Rico should recognize *res ipsa loquitur* as a distinct evidentiary doctrine in negligence actions governed by Civil Code article 1802.
2. Whether the plaintiff proved negligence and adequate causation under article 1802 when the principal proof was that the bottle exploded during handling associated with the warehouse.

## Decision

- The Supreme Court reversed the judgment for the plaintiff.
- The Court rejected continued use of *res ipsa loquitur* as a separate doctrine in Puerto Rico tort cases.
- Applying ordinary article 1802 analysis and general evidentiary rules, the Court held the plaintiff failed to prove negligent conduct and, particularly, a causal link between the warehouse’s practices and the bottle’s explosion.
- The defendants were relieved of liability because the record did not support a finding of negligence without reliance on a *res ipsa*-style presumption.

## Legal Principles

- Puerto Rico tort liability is governed, in form and content, by civil-law rules under Civil Code article 1802.
- *Res ipsa loquitur* is not an independent doctrinal device in Puerto Rico and should not be used to create special presumptions or burden-shifting in negligence cases.
- Negligence and causation may be established through direct or circumstantial evidence, but the occurrence of an accident alone does not prove fault or causation.
- A plaintiff must prove: (1) negligent or wrongful act or omission, (2) damages, and (3) an adequate causal nexus; circumstantial inferences must be grounded in facts that make defendant-caused negligence more probable than alternative causes.

## Conclusion

The Puerto Rico Supreme Court eliminated *res ipsa loquitur* as a distinct doctrine and required negligence claims under Civil Code article 1802 to be resolved through ordinary proof rules, including circumstantial evidence, without treating an accident’s mere occurrence as sufficient proof of fault or causation.


Bacó ex rel. Castillo de Jesús v. Almacén Ramón Rosa Delgado, Inc., 151 D.P.R. 711 (P.R. 2000)