The earliest I could locate was a Mexican film El Tren fantasma as described here.
The General (1926) starring Buster Keaton was known for its action in a train, but I am unable to reliably establish if there was a fight on top of a moving train.
Is there any older movie which has such a fight?
Answer
The oldest I know is "The Great Train Robbery" (1903).
There is a youtube clip, see scene 4, approx. in minute 4ff
There are more information about the film at:
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