G.R. No. L-11489 - People vs. Uy Jui Pio

The appellant, Uy Jui Pio, was charged in the municipal court of Manila with violating Commonwealth Act No. 142.
The specific charge was for publicly using a name different from the one with which he was christened or had been known since childhood.

At the trial, the appellant admitted that he had been known since childhood by the name "Uy Jui Pio alias Juanito Uy."
He further admitted that during his school years he was known by the same dual designation – "Uy Jui Pio alias Juanito Uy."
Records from the Bureau of Immigration (dating from 1946) also reflected the name "Uy Jui Pio alias Juanito Uy."
He stated that from 1936 up to the enactment of Commonwealth Act No. 142, he had been using that name consistently.
Additionally, in his marriage contract, he signed as "Juanito Uy" to match a preprinted name on the document.

Based on his admissions, the trial court found that Uy Jui Pio had violated section 2 of Commonwealth Act No. 142.
The trial court ruled that he adopted the name "Juanito Uy" despite already being named "Uy Jui Pio" in his country.

Prohibits any person from using a name different from the one with which he was christened or had been known since childhood, except as a pseudonym for literary purposes.
It implies that one is authorized to use the name by which he has been known since childhood.

Provides that any person wishing to use an alias must obtain judicial authorization, detailing the original name and the alias in separate proceedings.
This section, by construction, aims to regulate the use of unauthorized aliases.

The Court of Appeals certified the appeal to raise solely a question of law.
The case then reached the Supreme Court for resolution of the legal issue regarding the interpretation of Commonwealth Act No. 142.

Whether the appellants' consistent use of the name "Juanito Uy" since childhood falls under the authorization provided by section 1 of Commonwealth Act No. 142.
Whether the application of section 2 — requiring judicial authorization for the use of an alias — is warranted given that "Juanito Uy" was also the name by which the appellant had been known since childhood.

How should the two sections of the Act be construed together to avoid any conflict?
Whether a strict interpretation of the penal statute favors the State or the accused in this context.