FACTS:

The case involves the death of Nicanor Navidad, who fell onto the tracks of an LRT train during a fist fight with a security guard named Junelito Escartin. Marjorie Navidad, Nicanor's widow, filed a complaint for damages against Escartin, Rodolfo Roman (the operator of the train), LRTA, Metro Transit, and Prudent Security Agency. The Regional Trial Court found LRTA and Roman liable for damages but exonerated Prudent. On appeal, the Court of Appeals held LRTA and Roman liable for Nicanor's death, reasoning that a contract of carriage existed between Nicanor and LRTA even though he had not yet boarded the train. Prudent appealed to the Supreme Court.

ISSUES:

1. Whether the Court of Appeals erred in disregarding the findings of facts by the trial court.

2. Whether the Court of Appeals erred in finding the petitioners liable for the death of Nicanor Navidad, Jr.

3. Whether the Court of Appeals erred in finding that Rodolfo Roman is an employee of LRTA.

RULING:

1. The Court denies the appeal and affirms the decision of the Court of Appeals. The Court of Appeals did not err in its findings and conclusion that the LRTA and Rodolfo Roman are liable for the death of Nicanor Navidad. However, the Court modifies the damages awarded to the plaintiffs-appellees.

PRINCIPLES:

• A common carrier is presumed to have been negligent if it fails to prove that it exercised the utmost diligence in ensuring the safety of its passengers.

• The existence of an employer-employee relationship is a question of fact that is best determined by the trial court based on the evidence presented.