1. ANGEL T.

LIMJOCO, petitioner,
vs.
INTESTATE ESTATE OF PEDRO O. FRAGRANTE, deceased, respondent.G.R.
No. L-770
April 27, 1948

FACTS:
Pedro O. Fragante applied for a certificate of public convenience to install,
maintain and operate an ice plant in San Juan, Rizal. The Public Service
Commission approved the application and held that evidence showed that
the public interest and convenience will be promoted in a proper and
suitable manner by the authorization of the operation of another ice-plant,
that Pedro Fragante was a Filipino Citizen at the time of his death and that
his intestate estate is financially capable of maintaining the proposed
service. The commission ordered that a certificate of public convenience be
issued to the Intestate Estate of the deceased Pedro Fragante.
Petitioner contends that the commission erred in allowing the substitution
of the legal representative of the estate of Pedro O. Fragante for the latter
as party applicant, and in subsequently granting to said estate the
certificate applied for, which is said to be in contravention of law.

ISSUE:
Whether the estate of Pedro O. Fragrante is a “person”.

HELD:
Yes. The SC cited the SC of Indiana which held that “The estate of the decedent is
a person in legal contemplation. The word “person” in its legal signification, is a
generic term, and includes artificial as well as natural persons.” It said in another
work that ‘persons are of two kinds: natural and artificial. A natural person is a
human being. Artificial persons include (1) a collection or succession of natural
persons forming a corporation;; (2) a collection of property to which the law
attributes the capacity of having rights and duties. The latter class of artificial
persons is recognized only to a limited extent in our law.”
Under the present legal system, such rights and obligations as survive after death
have to be exercised and fulfilled only by the estate of the deceased. And if the
same legal fiction were not indulged, 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.
The underlying reason for the legal fiction by which, for certain purposes, the
estate of the deceased person is considered a “person” is the avoidance of
injustice or prejudice resulting from the impossibility of exercising such legal rights
and fulfilling such legal obligations of the decedent as survived after his death
unless the fiction is indulged.
Moreover, the citizenship of Fragrante is also extended. The fiction of such
extension of his citizenship is grounded upon the same principle, and motivated
by the same reason, as the fiction of the extension of personality. The fiction is
made necessary to avoid the injustice of subjecting his estate, creditors and heirs,
solely by reason of his death to the loss of the investment amounting to P35,000,
which he has already made in the ice plant, not counting the other expenses
occasioned by the instant proceeding, from the Public Service Commission of this
Court.
2. Ibarle vs. Po G.R. No. L-5064
Facts:
 The case involves a dispute over the sale of a deceased husband's property
by his widow.
 The deceased, Leonard J. Winstanley, left behind his surviving spouse,
Catalina Navarro Vda. de Winstanley, and some minor children.
 Catalina sold the entire parcel of land to the spouses Maria Canoy and
Roberto Canoy, claiming that she needed money for the support of her
children.
 The Canoy spouses sold the same property to the plaintiff, Bienvenido A.
Ibarle.
 Both sales were not registered.
  Catalina, after being appointed as the guardian of her children, sold one-
half of the land to the defendant, Esperanza M. Po.
Issue:
 The main issue is the validity of the sale made by Catalina to Esperanza.
 This issue is dependent on the validity of the prior sale made by Catalina to
the Canoy spouses.
Ruling:
 The court declared the sale made by Catalina to Esperanza as legal and
effective.
 The prior sale to the Canoy spouses was deemed null and void insofar as it
included the children's share.
Ratio:
 The court based its decision on the principle that the rights to the
succession of a person are transmitted from the moment of their death.
 No formal or judicial declaration is needed to confirm the children's title to
the inheritance.
 When Catalina sold the property to the Canoy spouses, one-half of it
already belonged to the children.
 As a result, the first sale was deemed null and void insofar as it included the
children's share.
3. Lorenzo vs. Posadas, Jr. G.R. No. 43082
Facts:
 The case is Lorenzo v. Posadas, Jr., decided by the Philippine Supreme Court
on June 18, 1937.
 The plaintiff, Pablo Lorenzo, as trustee of the estate of Thomas Hanley,
deceased, brought the action against the defendant, Juan Posadas, Jr., the
Collector of Internal Revenue.
 The plaintiff sought a refund of the inheritance tax paid on the estate of the
deceased.
 The plaintiff argued that the tax should be based on the value of the estate
ten years after the testator's death.
 The defendant argued that the tax should be based on the value of the
estate at the time of the testator's death.
Issue:
 When does the inheritance tax accrue and when must it be satisfied?
 Should the inheritance tax be computed on the basis of the value of the
estate at the time of the testator's death, or on its value ten years later?
 Is it proper to deduct the compensation due to trustees in determining the
net value of the estate subject to tax?
 What law governs the case? Should the provisions of Act No. 3606 favorable
to the taxpayer be given retroactive effect?
 Has there been delinquency in the payment of the inheritance tax? If so,
should the additional interest claimed by the defendant be paid by the
estate?
Ruling:
 The inheritance tax accrues at the moment of death and should be based
on the value of the estate at that time.
 The tax should not be affected by any subsequent increase or decrease in
the value of the estate.
 The compensation due to trustees should not be deducted in determining
the net value of the estate subject to tax.
 Act No. 3606, enacted after the testator's death, should not be given
retroactive effect.
 There has been delinquency in the payment of the inheritance tax.
 The estate is ordered to pay the additional interest and surcharge as
provided by law.
Ratio:
 The court held that the inheritance tax accrues at the moment of death and
should be based on the value of the estate at that time. This means that any
subsequent increase or decrease in the value of the estate should not affect
the computation of the tax.
 The court reasoned that the purpose of the inheritance tax is to impose a
burden on the privilege of receiving property by inheritance. Therefore, it is
 just and proper to base the tax on the value of the estate at the time of the
testator's death.
 The court also ruled that the compensation due to trustees should not be
deducted in determining the net value of the estate subject to tax. The
compensation is a separate matter and should not be considered as part of
the estate for tax purposes.

4. Tadeo-Matias vs. Republic G.R. No. 230751

Facts:
 Petitioner Estrellita Tadeo-Matias filed a petition for the declaration of
presumptive death of her husband, Wilfredo N. Matias, who went missing
in 1979.
 The Regional Trial Court (RTC) granted the petition.
 The Court of Appeals set aside the decision of the RTC, stating that the RTC
erred in declaring Wilfredo presumptively dead based on Article 41 of the
Family Code.
Issue:
 Whether or not a judicial declaration of presumptive death is necessary for
the granting of benefits to the claimant.
Ruling:
 The Supreme Court affirms the decision of the Court of Appeals.
Ratio:
 The court explains that a judicial declaration of presumptive death is not
required for the granting of benefits.
 The court criticizes the practice of requiring claimants to secure a court
declaration of presumptive death before processing death benefits.
 The court provides guidelines for handling death benefit claims.

5. Blas vs. Santos G.R. No. L-14070

Facts:
 The case involves a dispute over a promise made by Maxima Santos to
deliver one-half of the conjugal properties to the plaintiffs upon her death
and in her will.
 The promise was stated in a document called Exhibit "A".
 Maxima Santos passed away and her will was presented in court.
 The plaintiffs argued that the will did not comply with the promise made
in Exhibit "A".
Issue:
 Whether the promise made by Maxima Santos in Exhibit "A" is a valid
trust agreement and compromise.
 Whether Maxima Santos' will complied with the promise made in Exhibit
"A".
Ruling:
 The promise made by Maxima Santos in Exhibit "A" is a valid trust
agreement and compromise.
 Maxima Santos' will did not comply with the promise made in Exhibit "A".
Ratio:
 The court held that Exhibit "A" was a valid trust agreement and
compromise.
 The court found that Maxima Santos promised to transmit one-half of her
share in the conjugal properties to the heirs and legatees of her husband.
 The court determined that Exhibit "A" was not a contract on future
inheritance, but rather a promise to transmit the properties.

6. Tuason, Jr. vs. Lingad G.R. No. L-24248

Facts:
Antonio Tuason, Jr. inherited several tracts of land from his mother, including
two parcels in Manila.
One of the parcels, referred to as Lot 29, was not leased to anyone and needed
filling due to its low elevation.
In 1952, Tuason's attorney-in-fact had Lot 29 filled, subdivided into small lots,
and paved with macadam roads.
The small lots were then sold on a 10-year annual amortization basis.
Tuason reported his income from the sale of the small lots as long-term capital
gains in 1953 and 1954.
In 1963, the Commissioner of Internal Revenue reversed his previous ruling and
considered the profits from the sales as ordinary gains.
Tuason filed a motion for reconsideration, which was denied, leading him to
appeal to the Court of Tax Appeals.
Issue:
Whether the properties sold by Tuason should be considered as capital assets or
ordinary assets for tax purposes.
Ruling:
The Court of Tax Appeals affirmed the Commissioner's decision, ruling that the
gains from the sale of the properties were ordinary gains and not gains from the
sale of capital assets.
The court also ordered Tuason to pay a 5% surcharge and 1% monthly interest.
However, the Supreme Court, in its decision, affirmed the ruling of the Court of
Tax Appeals but set aside the additional requirement of the surcharge and
interest.
Ratio:
The term "capital assets" includes all properties of a taxpayer, except for stock in
trade, property primarily for sale to customers, property used in trade or
business subject to depreciation allowance, and real property used in the
taxpayer's trade or business.
In determining whether a property is a capital asset or an ordinary asset, all
circumstances relevant to the case must be considered.
7. DKC Holdings Corp. vs. Court of Appeals G.R. No. 118248
Facts:
 DKC Holdings Corporation (petitioner) and Encarnacion Bartolome entered
into a Contract of Lease with Option to Buy.
 The contract allowed DKC to lease or lease with purchase a parcel of land
owned by Encarnacion Bartolome.
 DKC could take possession of the premises for a period of six years,
renewable for another six years, and pay a monthly rental fee.
 DKC regularly paid the reservation fee to Encarnacion until her death in
January 1990.
 After her death, DKC continued to pay the reservation fees to Victor
Bartolome, the sole heir of Encarnacion, but Victor refused to accept the
payments.
 DKC served notice to Victor that it was exercising its option to lease the
property, but Victor refused to accept the rental fee and surrender
possession of the property.
 DKC opened a savings account in Victor's name and deposited the rental
and reservation fees there.
 When DKC tried to register and annotate the contract on the title of the
property, the Register of Deeds refused to do so.
 DKC filed a complaint for specific performance and damages against Victor
and the Register of Deeds.
 The trial court dismissed the complaint, and the Court of Appeals affirmed
the decision.
Issue:
  Whether the Contract of Lease with Option to Buy was terminated upon
the death of Encarnacion Bartolome or if it binds her heir, Victor
Bartolome.
Ruling:
 The contract was not terminated by Encarnacion's death, and Victor, as
her heir, is bound by the contract.
 Victor Bartolome is ordered to surrender and deliver possession of the
property to DKC and perform all obligations under the contract.
 The Register of Deeds is ordered to register and annotate the contract on
the title of the property.
Ratio:
 Article 1311 of the Civil Code states that contracts take effect between the
parties, their assigns, and heirs unless the rights and obligations under the
contract are not transmissible by nature, stipulation, or provision of law.
8. Rupa, Sr. vs. Court of Appeals G.R. No. 80129
Facts:
 Gerardo Rupa Sr. claimed to be the agricultural share tenant of a coconut
land owned by the Lims for more than 20 years.
 The Lims sold the property to Magin Salipot without giving any prior
notice to Rupa.
 Rupa wanted to exercise his right of redemption over the property.
 Both the trial court and the Court of Appeals ruled against Rupa.
 The Court of Appeals held that there was no evidence to prove Rupa's
tenancy and that Rupa had admitted in another case that he was the
overseer and administrator of the land.
 The Office of the Treasurer issued a certificate stating that Rupa was a
copra buyer during a certain period.
 Rupa filed a petition for review before the Supreme Court.
Issue:
 Whether Rupa's claim of tenancy is valid and if he is entitled to exercise
his right of redemption.
Ruling:
 The Supreme Court found that the trial court and the appellate court
overlooked and disregarded the overwhelming evidence in favor of Rupa.
 The factual findings of the lower courts were not conclusive because they
were based on the supposed absence of evidence, which was contradicted
by evidence on record.
 The court applied the exception of non-conclusiveness in this case due to
compelling reasons.
 Rupa was found to be a tenant of the subject land and was entitled to
exercise his right of redemption.
Ratio:
 Whether a person is a tenant or not is generally a question of fact, but
there are compelling reasons to apply the exception of non-
conclusiveness in this case.
 A tenant is defined as a person who cultivates the land belonging to or
possessed by another, with the latter's consent, for purposes of
production and sharing the produce with the landholder.
 The passing statements in the decision of another case and the certificate
from the Office of the Treasurer were not sufficient to disprove Rupa's
claim of tenancy.

9. Blas vs. Santos G.R. No. L-14070

10.Tuason, Jr. vs. Lingad G.R. No. L-24248
11.Reyes vs. Regional Trial Court of Makati, Branch 142 G.R. No. 165744
Facts:
  The case involves a family dispute over the ownership of shares in Zenith
Insurance Corporation.
 The petitioner, Oscar C. Reyes, and the respondent, Rodrigo C. Reyes, are
two of the four children of Pedro and Anastacia Reyes, who owned shares
in Zenith.
 After the death of their parents, a dispute arose regarding the distribution
of Anastacia's shareholdings in Zenith.
 Rodrigo filed a complaint with the Securities and Exchange Commission
(SEC) against Oscar, seeking an accounting of the funds and assets of
Zenith and the determination of the shares of stock of their deceased
parents that were allegedly appropriated by Oscar.
 The case was transferred to the Regional Trial Court (RTC) when Republic
Act No. 8799 took effect.
 Oscar filed a motion to declare the complaint as a nuisance or harassment
suit, arguing that it was not a bona fide derivative suit and that it should
be filed as a petition for settlement of the estate.
 The RTC denied the motion, and the Court of Appeals affirmed the
decision.
 Oscar appealed to the Supreme Court.
Issue:
 Whether the RTC, acting as a special commercial court, has jurisdiction
over Rodrigo's complaint.
Ruling:
 The RTC does not have jurisdiction over the case.
Ratio:
 The Court applied the relationship test and the nature of the controversy
test to determine jurisdiction.
 Under the relationship test, the controversy must arise out of intra-
corporate or partnership relations between the parties.
 The Court found that Rodrigo, as an heir of Anastacia, did not have an
intra-corporate relationship with Zenith and therefore the relationship
test was not satisfied.
 Under the nature of the controversy test, the controversy must pertain to
the enforcement of the parties' correlative rights and obligations under
the Corporation Code.
 The Court found that the controversy in this case was purely civil in nature
and related to the protection and enforcement of successional rights, not
corporate rights.