Title
Supreme Court
Light Rail Transit Authority vs. Navidad
Case
G.R. No. 145804
Decision Date
Feb 6, 2003
Intoxicated Nicanor Navidad fell onto LRT tracks after altercation with security guard, struck by train. LRTA held liable for failing to ensure passenger safety; Roman, Prudent Security absolved. Nominal damages deleted.

Case Digest (G.R. No. 145804)
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)

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