G.R. No. L-63817 - Legamia y Rivera vs. Intermediate Appellate Court

The petitioner, Corazon Legamia, was prosecuted in the now-defunct Court of First Instance of Manila for allegedly using an alias in violation of Commonwealth Act No. 142, as amended.
The trial court found her guilty and sentenced her to an indeterminate prison term ranging from one (1) year to two (2) years, imposed a fine of P5,000.00 with subsidiary imprisonment, and ordered payment of costs.
The trial court recommended that the petitioner be considered for executive clemency.
The decision was affirmed in toto by the Intermediate Appellate Court, prompting the petitioner to file an appeal by certiorari.

Corazon Legamia lived in a long-term cohabitation arrangement with Emilio N. Reyes for 19 years (from November 8, 1955, to September 26, 1974).
During this period:

She was known to the public as Corazon L. Reyes and even styled herself as Mrs. Reyes.
Emilio N. Reyes consistently introduced her to friends and associates as his wife.

The couple had a child, Michael Raphael Gabriel L. Reyes, born on October 18, 1971, whose legitimacy in terms of social recognition was enhanced by the petitioner’s use of the Reyes surname.

Upon the death of Emilio N. Reyes in September 1974, Corazon, nearly immediately after his passing, filed a claim with the Agricultural Credit Administration on behalf of Michael, signing the document as “Corazon L. Reyes.”
The voucher evidencing the payment of Michael’s claim (amounting to P2,648.76) was also signed using the name “Corazon L. Reyes.”
Felicisima Reyes, who was married to Emilio, initiated a complaint leading to the prosecution because Corazon’s use of the Reyes surname was alleged to be an impersonation contrary to the prescribed legal name requirements.

Commonwealth Act No. 142, as amended by R.A. No. 6085, governs the proper use of one’s name.
Section 1 of the Act mandates that no person may use any name different from the one registered at birth or used upon baptism, except in specified circumstances (e.g., pseudonyms for entertainment or athletic events).
The Act permits the use of a substitute name only if such change has been authorized by a competent Court.
The charge against Corazon was based on the alleged violation of this provision.

Whether the petitioner’s act of using the surname Reyes (which was not her birth name) constituted a violation of Commonwealth Act No. 142.

Does the long-term cohabitation and public representation as the wife of Emilio N. Reyes exempt her from the restrictions imposed by the law?
Was there any fraudulent, sinister, or material intent in her assuming the Reyes name in the context of securing benefits for her dependent child?
How should culturally ingrained practices, such as using the name of a live-in partner, be reconciled with the strict interpretation of the statutory provision?