Light Rail Transit Authority & Rodolfo Roman v. Marjorie Navidad

Summary

This case involves the death of Nicanor Navidad at an EDSA LRT station following an altercation with security guard Junelito Escartin. The Supreme Court held that a contract of carriage was established when Navidad paid his fare and entered the station premises, making LRTA liable as a common carrier under the presumption of negligence for passenger safety. The Court applied Civil Code provisions requiring extraordinary diligence from common carriers and found that LRTA failed to overcome this presumption. However, the Court absolved both Prudent Security Agency (due to lack of proof of employee negligence) and train operator Rodolfo Roman (no showing of personal fault). The decision modified the Court of Appeals ruling by deleting nominal damages and removing Roman's liability, while affirming LRTA's responsibility for actual damages, moral damages, death indemnity, and attorney's fees. The case establishes important precedent on common carrier liability extending to passenger safety within station premises before actual boarding.