Angel Limjoco vs Intestate Estate of Pedro Fragrante

written by Howard

G.R. No. L-770 – 80 Phil. 776 – Remedial Law – Special Proceedings – Settlement of Estate – Estate as an artificial person

Pedro Fragrante applied for a certificate of public convenience (CPC) to operate another ice plant in San Juan, Rizal. Angel Limjoco, the owner of the existing ice plant, opposed the application of Fragrante on the ground that their ice plant is more than capable to supply the needs of the locals. While the application was pending consideration, Fragrante died. Despite his death, the Public Service Commission issued the CPC but since Fragrante died, the CPC was issued in favor of Fragrante’s estate.

Limjoco questioned the propriety of the grant on the grounds that (1) the estate of Fragrante has no personality and (2) CPCs can only be issued to Filipino citizens and the estate has no citizenship.

ISSUE: Whether or not the objections of Limjoco are correct.

HELD: No.  The estate of a deceased person is considered as having legal personality. Persons can either be natural or artificial (juridical). An estate is an artificial person. It is a personality distinct from the heirs of the decedent. When a person dies, his personality is extended through the estate. The estate or the mass of property, rights and assets left by the decedent becomes vested and charged with his or her rights and obligations which survive after his demise.

The Supreme Court discussed that under the old Civil Code, the doctrine then was that the personality of a deceased person is extended through his or heirs. But with the innovations brought by the Code of Civil Procedure, it is now the estate that extends the personality of the deceased.

Under the present legal system, rights and obligations which survived the death of the decedent have to be exercised and fulfilled only by the estate of the deceased. Otherwise, there would be no juridical basis for the estate, represented by the executor or administrator, to exercise those rights and to fulfill those obligations of the deceased.

Anent the issue of citizenship, the estate, being the extension of the personality of the deceased, takes the citizenship of the deceased.

NOTE: As can be gleaned from this case, the personality of a deceased person is not extended through his or heirs. For if that would be the case, obligations, such as debts, will be shouldered by the heirs and not the estate.

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