Case Title: Cesario Ursua vs. Court of Appeals and People of the Philippines
Case Number: G.R. No. 112170, April 10, 1996
Doctrine/Relevant Topic: Construction of penal laws
Facts:
Atty. Palmones asked Cesar Ursua to deliver his letter-request to the Ombudsman’s office because his law firm messenger, Oscar Perez, had to attend to some personal matters. Oscar Perez instructed Ursua that if an acknowledgment receipt is required, he can sign the receipt with his name.
He wrote Oscar Perez in the visitor’s logbook upon entering the Office of the Ombudsman in Davao City, then went to the Administrative Division and gave the letter-request of Atty. Palmones to Chief of the Administrative Division, Ms. Loida, who gave him a copy of the complaint, which he acknowledged by writing the name Oscar Perez. As he was about to leave, Ursua ran into an acquaintance, Josefa Amparo, who also worked for the same office, before leaving the premises. Ms. Loida discovered that the individual who introduced himself as Oscar Perez was actually Cesario Ursua after Ursua left. She then informed the Deputy Ombudsman about the situation.
He was found guilty of violating Sec. 1 C.A.142, as amended by R.A. 6085, by the trial court. The petitioner took his case to the Court of Appeals.
Ursua filed a petition with the Court of Appeals, which upheld his conviction by the Davao City Regional Trial Court for violating Sec. 1 C.A. 142 as amended by R.A. 6085, also known as “An Act to Regulate the Use of Aliases.”
In order to reaffirm his innocence, he has filed a petition for a judicial review of his conviction. He did not break Section 1 of CA 142, as amended by R.A. 6085. He has never used an alias name, and Oscar Perez is not one of them. According to him, a “Alias” is a term that refers to a person who is also known by another name. He maintains that he has never been known as “Oscar Perez” and that he has only used the name with Oscar Perez’s express permission on one occasion. He further claims that the Court of Appeals erred in dismissing his defense argument that he was prosecuted under the wrong statute.
Issues:
- Whether or not Cesario Ursua is liable under Sec.1 CA 142 as amended by R.A. 6085 for using an Alias; and
- Whether or not the conviction of Cesario Ursua is proper.
Ruling:
The Supreme Court ruled in the negative. Accordingly, Ursua should be acquitted. The Court ruled that a strict application of C.A. No. 142, as amended, in this case would result in absurdity, which the lawmakers could not have intended.
It is clear, according to the Court, that alias is a name or names used by a person or intended to be used by him publicly and habitually usually in business transactions in addition to his real name by which he is registered at birth or baptized the first time or substitute name authorized by a competent authority.
The use of an alias is forbidden under the law if it is employed habitually and publicly in business dealings without prior authorization from a competent authority. In this case, Ursua only used the name “Oscar Perez” once, it was not used in a business transaction, the use of the name was with Oscar Perez’s authorization, and even if he used a different name, he was not even needed to divulge his identity at the Office of the Ombudsman. He did not have to reveal his identify while getting a copy of the complaint because it is a public record open to the public. There is no question then that “Oscar Perez” is not an alias name of petitioner. There is no evidence showing that he had used or was intending to use that name as his second name in addition to his real name.
Thus, the evils sought to be avoided by C.A. No. 142 were not caused by Ursua’s use of a name other than his own. A rigid application of the law is not warranted. There was no fraud committed when Ursua used the name Oscar Perez, hence there was no crime committed punishable under C.A. No. 142. The objective of the law is to punish misdeeds defined in it, thus since Ursua’s behavior did not cause such evil, the law does not need to be applied.
The act of petitioner may be covered by other provisions of law; such does not constitute an offense within the concept of C.A. No. 142 as amended under which he is prosecuted.
The Court ruled to acquit the petitioner Cesario Ursua of the crime charged. The questioned decision of the Court of Appeals affirming that of the Regional Trial Court of Davao City was reversed and set aside.
