Case Summary (G.R. No. 145804)
Procedural History
On December 8, 1994, Marjorie Navidad and her children filed a damage suit against Escartin, Roman, LRTA, Metro Transit Organization, Inc., and Prudent Security Agency for the death of Nicanor Navidad. The Regional Trial Court (Pasig City, Branch 266) rendered judgment on August 11, 1998, holding Prudent and Escartin liable and dismissing claims against LRTA and Roman. Prudent appealed. On April 27, 2000, the Court of Appeals exonerated Prudent and instead held LRTA and Roman jointly liable. The appellate court denied reconsideration on October 10, 2000. LRTA and Roman filed the present petition.
Facts
On October 14, 1993, at about 7:30 PM, an inebriated Nicanor Navidad purchased a token and entered the EDSA LRT station platform. An altercation ensued between Navidad and station guard Escartin, resulting in a fistfight. Navidad fell onto the tracks as an LRT train—operated by Roman—approached. He was struck and killed instantly.
Trial Court Decision
The trial court found Prudent (through Escartin) liable for negligence that led to Navidad’s fall. It awarded actual damages (P44,830), compensatory damages (P443,520), indemnity (P50,000), moral damages (P50,000), attorney’s fees (P20,000), and costs. It dismissed the complaint against LRTA and Roman and denied their counterclaims.
Court of Appeals Decision
The Court of Appeals modified the judgment by exonerating Prudent and Escartin, and held LRTA and Roman jointly liable. It awarded actual damages (P44,830), nominal damages (P50,000), moral damages (P50,000), indemnity (P50,000), and attorney’s fees (P20,000). The appellate court reasoned that a contract of carriage arose when Navidad paid the fare and entered the station, invoking the strict-duty presumption against common carriers.
Issues on Appeal
LRTA and Roman assert that (i) the appellate court ignored the trial court’s factual findings, (ii) they were erroneously held liable, and (iii) the court erred in concluding that Roman is LRTA’s employee.
Applicable Law
1987 Philippine Constitution; Civil Code of the Philippines, Articles 1755, 1756, 1759, 1763 (common carrier liability), Articles 2176, 2180, and 2194 (quasi-delict and solidary liability).
Liability of Common Carriers
Under Articles 1755 and 1756, a common carrier owes passengers utmost diligence and is presumed negligent in case of injury or death unless it proves extraordinary diligence. Article 1759 extends liability for employees’ negligent acts, and Article 1763 imposes liability for third-party acts if the carrier could have prevented them by exercising due diligence. A contract of carriage—along with its protective duties—attaches upon payment of fare and entry to the carrier’s premises.
Prudent Security Agency’s Liability
Liability of an employer or principal in quasi-delict rests on the employee’s negligence. Prudent’s employee, Escartin, was presumed negligent only if evidence showed he caused the fatal fall. The Court found no proof linking Escartin’s co
...continue readingCase Syllabus (G.R. No. 145804)
Procedural History
- Original complaint filed on December 8, 1994 by Marjorie Navidad and her children for damages arising from the death of Nicanor Navidad against Junelito Escartin, Rodolfo Roman, the LRTA, Metro Transit Organization, Inc., and Prudent Security Agency.
- LRTA and Roman interposed a compulsory counterclaim against Navidad and a cross-claim against Escartin and Prudent.
- Prudent denied liability and invoked due diligence in selecting and supervising its security guards.
- On August 11, 1998, the Regional Trial Court, Branch 266, Pasig City:
- Held Prudent and Escartin jointly and severally liable for actual, compensatory, indemnity, moral damages, attorney’s fees, and costs.
- Dismissed the complaint and the counterclaim against LRTA and Roman for lack of merit.
- Prudent appealed to the Court of Appeals (CA-G.R. CV No. 60720).
- On April 27, 2000, the Court of Appeals modified the trial court judgment by:
- Exonerating Prudent Security Agency from all liability.
- Holding LRTA and Roman jointly and severally liable for actual, nominal, moral damages, indemnity, and attorney’s fees.
- The CA denied petitioners’ motion for reconsideration on October 10, 2000.
- Petitioners elevated the case to the Supreme Court under G.R. No. 145804; decision promulgated February 7, 2005.
Facts
- On October 14, 1993, at about 7:30 PM, Nicanor Navidad, in an intoxicated state, entered the EDSA LRT station and paid the fare by obtaining a token.
- Navidad stood on the platform near the tracks.
- Junelito Escartin, the security guard assigned to that area, approached and, for reasons not shown by the evidence, a fistfight ensued between Escartin and Navidad.
- There is no proof of who struck first or how Navidad fell onto the tracks.
- Immediately as Navidad fell, an LRT train operated by Rodolfo Roman struck him, causing instantaneous death.
Trial Court Findings
- The trial court found Prudent Security Agency and its employee, Junelito Escartin, liable for negligence leading to the death of Nicanor Navidad.
- It concluded there was insufficient evidence to hold LRTA or Rodolfo Roman responsible.
- Awards granted to the pla