Limjoco v. Intestate Estate of PioFragante, 80 Phil 776

FACTS: Pedro Fragante, a Filipino citizen at the time of his death, applied for a certificate of public convenience to install and maintain an ice plant in San Juan, Rizal. His intestate estate is financially capable of maintaining the proposed service. The Public Service Commission issued a certificate of public convenience to Intestate Estate of the deceased through its special or judicial administrator appointed by the proper court of competent jurisdiction to maintain and operate the said plant. Petitioner claims that the granting of certificate applied to the estate is a contravention of law.

ISSUE: W/N the estate of Fragante may be extended an artificial judicial personality

HELD: Yes, because under the Civil Code, “estate of a dead person could be considered as artificial juridical person for the purpose of settlement and distribution of his properties.” Fragante has rights and fulfillment of obligation which survived after his death. One of those rights involved the pending application for public convenience before the PSC. The state or the mass of property, rights left by the decedent, instead of heirs directly, become vested and charged with his rights and obligations. Under the present legal system, rights and obligations which survived after death have to be exercised and fulfilled only by the estate of the deceased.