LIGHT RAIL TRANSIT AUTHORITY & RODOLFO ROMAN, VS.

MARJORIE NAVIDAD, Heirs of the Late NICANOR NAVIDAD &

PRUDENT SECURITY AGENCY,
GR NO 145804, FEBRUARY 6, 2003
Vitug, J.

Facts:
On October 14, 1993, around seven (7) o’clock in the evening, Nicanor Navidad, then
drunk, entered the EDSA LRT station after purchasing a token (representing payment of fare).
While Navidad was standing near the LRT tracks, a misunderstanding or an altercation between
Junelito Escartin, security guard, apparently ensued that led to a fistfight. Thereafter, Navidad
fell on the LRT tracks and was struck by the moving train, operated by petitioner Rodolfo
Roman. Navidad was killed instantaneously. Thus, on December 8, 1994, the widow of Nicanor
and his children, herein respondent, filed a complaint for damages against Escartin, Roman,
the LRTA, Metro Transit and Prudent Security.
The trial court rendered its decision in favor of plaintiffs and against the defendants
Prudent Security and Escartin. The Court of Appeals, however, rendered its decision
exonerating Prudent Security and, instead, holding the LRTA and Roman liable for the death
of Nicanor.

Issue:
WON LRTA is liable for the death of Nicanor Navidad.

Held:
Yes, LRTA is liable for the death of Nicanor Navidad because, under the law and
jurisprudence, a common carrier both from the nature of its business and for reasons of public
policy, is burdened with the duty of exercising utmost diligence in ensuring the safety of
passenger. Article 1755, Article 1756, Article 1759, and Article 1763 governs the liability of a
common carrier for the death or injury to its passengers. In this case, the liability of LRTAs
liability is the contract of carriage and its obligation to indemnify the victims arises from the
breach of that contract by reason of its failure to exercise the high diligence required of the
common carrier. A carrier may choose to hire its own employees or avail itself of the service
of an outsider or an independent firm to undertake the task. In either case, the common carrier
is not relieved of its responsibilities under the contract of carriage. Hence, LRTA is liable for
the death of Nicanor Navidad.