Case Digest (G.R. No. 145804) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On the evening of October 14, 1993, around 7:30 PM, Nicanor Navidad, in an inebriated state, purchased a fare token and entered the EDSA LRT station platform. While standing near the tracks, he was approached by Junelito Escartin, a security guard employed by Prudent Security Agency. An unexplained altercation ensued, resulting in a fistfight during which Navidad fell onto the tracks. At that instant, an LRT train operated by petitioner Rodolfo Roman and owned by the Light Rail Transit Authority (LRTA) struck and killed Navidad instantly. On December 8, 1994, Marjorie Navidad, widow of the deceased, together with their children, filed an action for damages against Escartin, Roman, the LRTA, Metro Transit Organization, Inc., and Prudent. The LRTA and Roman counterclaimed against Navidad’s estate and cross-claimed against Escartin and Prudent. The Regional Trial Court (RTC) of Pasig City, Branch 266, in its August 11, 1998 decision, dismissed the complaint against the LRTA and R Case Digest (G.R. No. 145804) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Incident
- On 14 October 1993 at around 7:30 PM, Nicanor Navidad, intoxicated, entered the EDSA LRT station after purchasing a token.
- While standing on the platform, he was approached by Junelito Escartin, a security guard of Prudent Security Agency, leading to an unclarified fistfight.
- During the altercation, Navidad fell onto the tracks and was instantly killed by a train operated by Rodolfo Roman of the LRTA.
- Procedural History
- On 8 December 1994, Marjorie Navidad (widow) and children sued Escartin, Roman, LRTA, Metro Transit, and Prudent for damages. LRTA and Roman filed counterclaims; Prudent demurred.
- The Regional Trial Court (Branch 266, Pasig City) rendered judgment on 11 August 1998: it held Prudent and Escartin liable for actual, compensatory, moral damages, death indemnity, attorney’s fees, and costs; dismissed claims against LRTA and Roman; and dismissed LRTA/Roman’s counterclaims.
- Prudent appealed. On 27 April 2000 (decision) and 10 October 2000 (resolution), the Court of Appeals modified the trial court’s decision by exonerating Prudent and Escartin and holding LRTA and Roman jointly and severally liable for actual damages, nominal damages, moral damages, indemnity, and attorney’s fees.
- Petitioner LRTA and Roman elevated the case to the Supreme Court via a petition for review on certiorari.
Issues:
- Whether LRTA and its train operator Rodolfo Roman are liable as common carriers for the death of Navidad.
- Whether Prudent Security Agency can be held liable for tort/delict on the basis of its security guard’s alleged negligence.
- Whether Roman was an employee of LRTA (vicarious liability) or of Metro Transit (challenge to employer status).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)