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LIGHT RAIL TRANSIT AUTHORITY & RODOLFO ROMAN, vs.

MARJORIE NAVIDAD & PRUDENT


SECURITY AGENCY, G.R. No. 145804, February 6, 2003

On 1993, at 7:30 pm, Nicanor Navidad, then drunk, while standing on the platform near the LRT tracks,
was approached by a security guard. A misunderstanding between them ensued that led to a fight,
because of which Navidad fell on the tracks causing him to be struck and killed by the train. No evidence,
however, was adduced to indicate how the fight started and transpired. The widow of Nicanor, herein
respondent Marjorie Navidad, filed a complaint for damages against the train driver & security guard, the
LRTA, Metro Transit, and Prudent Security Agency. The RTC adjudged Prudent guilty while the complaint
against LRTA and train driver are dismissed for lack of merit. On appeal the CA exonerated Prudent from
liability and, held the LRTA and the train driver solidarily liable, rationing that while the deceased might not
have boarded the train, a contract of carriage theretofore had already existed when the victim entered the
place where passengers were supposed to be after paying the fare and getting the token therefor. In
exempting Prudent from liability. It said that Navidad failed to show that Escartin inflicted fist blows upon
the victim. The CA faulted petitioners for their failure to present expert evidence to establish the fact that
the application of emergency brakes could not have stopped the train.

ISSUE:

HELD: Law and jurisprudence dictate that a common carrier, from the nature of its business and reasons
of public policy, has the duty of exercising utmost diligence. Such duty of a common carrier obligates it not
only during the course of the trip but for so long as the passengers are within its premises and where they
ought to be in pursuance to the contract of carriage. The provisions rendering a common carrier liable for
death/injury to passengers (a) through the negligence or willful acts of its employees or b) the negligence
or wilful acts of other passengers/strangers, would apply if the common carriers employees through due
diligence could have prevented the act or omission. In case of such death or injury, a carrier is presumed
to have been at fault/negligent, and by simple proof of injury, the burden shifts upon the carrier to prove
that the injury is due to force majeure. In the absence of explanation by the carrier on how the accident
occurred, the presumption would be that it has been at fault, an exception from the general rule that
negligence must be proved. LRTAs liability is based on contract of carriage and its obligation to
indemnify the victim arises from the breach of thereof due to its failure to exercise the high diligence. In
the discharge of its commitment to ensure the safety of passengers, a carrier may choose to hire its own
employees or avail itself of the services of an outsider. In either case, the common carrier is not relieved
of its responsibilities under the contract of carriage. Moreover liability of the common carrier, and an
independent contractor, is solidary. A contractual obligation can be breached by tort and when the same
act or omission causes the injury, one resulting in culpa contractual and the other in culpa aquiliana. In
fine, a liability for tort may arise even under a contract, where tort is that which breaches the contract.
Stated differently, when an act which constitutes a breach of contract would have itself constituted the
source of a quasi-delictual liability had no contract existed between the parties, the contract can be said to
have been breached by tort, thereby allowing the rules on tort to apply. Regrettably this Court is
concluded by the factual finding of the CA that "there is nothing to link (Prudent) to the death of Nicanor.
There being, similarly, no showing that the train driver himself is guilty of any culpable act or omission, he
must also be absolved from liability. Needless to say, the contractual tie between the LRT and Navidad is
not itself a juridical relation between the latter and Roman; thus, Roman can be made liable only for his
own fault or negligence.

WHEREFORE, the assailed decision of the appellate court is AFFIRMED xxx


Metro Manila Transit Corp. vs. Reynaldo Cuevas and Junnel Cuevas, G.R. No. 167797, June 15, 20

MMTC and Mina's Transit entered into an agreement whereby the latter bought several bus units from the
former. They agreed that MMTC would retain the ownership of the buses until certain conditions were
met, but in the meantime Mina's Transit could operate the buses within Metro Manila. On 1994, one of the
aforementioned buses hit a Motorcycle owned by Reynaldo and driven by Junnel. they sued MMTC and
Mina's in RTC alleging that while Plaintiff was riding on their Motocycle, with a companion at the back,
along South Superhighway, defendants' driver Gaceta, heading in the same direction carelessly
attempted to overtake Plaintiffs. In its answer with compulsory counterclaim MMTC denied liability, and
averred that although it retained the ownership of the bus, the actual operator and employer of the bus
driver was Mina's Transit; and that, in support of its cross-claim against Mina's Transit, a provision in the
agreement to sell mandated Mina's Transport to hold it free from liability arising from the use and
operation of the bus units. On its part, Mina's Transit contended that it was not liable because: (a) it
exercised due diligence in the selection and supervision of its employees; (b) its bus driver exercised due
diligence; and (c) Junnel's negligence was the cause of the accident. RTC rendered judgment in favor of
Cuevas. The RTC concluded that the proximate cause of the mishap was the negligence of the bus
driver; On appeal, the CA affirmed. Thus MMTC appealed to this court urging us to the revisit of the
registered-owner rule in order to gain absolution from liability. It contends that although it retained
ownership of the bus at the time of the vehicular accident, the actual operation was transferred to Mina's
Transit;

ISSUE:

HELD: The appeal is partly meritorious. In view of MMTC's admission in its pleadings that it had remained
the registered owner of the bus at the time of the incident, it could not escape liability for the personal
injuries and property damage suffered by Cuevas. This is because of the registered-owner rule, whereby
the registered owner of the motor vehicle involved in a vehicular accident could be held liable for the
consequences. The registered-owner rule has remained good law in this jurisdiction considering its
impeccable and timeless rationale, as enunciated in the 1957 ruling in Erezo, v. Jepte, where the Court
pronounced: Registration is required not to make said registration the operative act by which ownership in
vehicles is transferred, as in land registration cases, because the administrative proceeding of registration
does not bear any essential relation to the contract of sale between the parties, but to permit the use and
operation of the vehicle upon any public highway. The main aim of motor vehicle registration is to identify
the owner so that if any accident happens, or that any damage or injury is caused by the vehicle on the
public highways, responsibility therefor can be fixed on a definite individual, the registered owner.
Instances are numerous where vehicles running on public highways caused accidents or injuries to
pedestrians or other vehicles without positive identification of the owner or drivers, or with very scant
means of identification. It is to forestall these circumstances, that the motor vehicle registration is primarily
ordained, No responsible person or corporation could be held liable for the most outrageous acts of
negligence, if they should be allowed to place a 'middleman' between them and the public, and escape
liability by the manner in which they recompense their servants." It is well settled that in case of motor
vehicle mishaps, the registered owner of the motor vehicle is considered as the employer of the
tortfeasor-driver who is considered as a mere agent of the former, and is made primarily liable for
the tort committed. The existence of an employer-employee relationship, as it is understood in labor
relations law, is not required. It is sufficient to establish that MMTC's is the registered owner. Indeed,
MMTC could not evade liability by passing the buck to Mina's Transit. The stipulation in the agreement to
sell did not bind third parties like the Cuevases, who were expected to simply rely on the data contained
in the registration certificate of the erring bus. Although the registered-owner rule might seem to be unjust
towards MMTC, the law did not leave it without any remedy or recourse. MMTC could recover from Mina's
Transit, the actual employer of the negligent driver, under the principle of unjust enrichment, by means of
a cross-claim seeking reimbursement of all the amounts that it could be required to pay as damages
arising from the driver's negligence.
WHEREFORE, the Court AFFIRMS the decision promulgated xxx