Case Digest (G.R. No. 112170)
Facts:
Petitioner Cesario Ursua, then a Community Environment and Natural Resources Officer assigned in Kidapawan, Cotabato, was implicated in a complaint for bribery and related charges filed with the Office of the Ombudsman following a 9 May 1989 resolution by the Sangguniang Panlalawigan. On 1 August 1989 he went to the Office of the Ombudsman in Davao to secure a copy of the complaint and registered himself as "Oscar Perez," signing the receipt with that name; the deception was discovered, he was tried under C.A. No. 142 as amended by R.A. No. 6085, convicted by the Regional Trial Court, and the Court of Appeals affirmed on 31 May 1993 with modification of penalty.
At trial petitioner filed a demurrer to evidence asserting that the prosecution failed to prove that the alleged alias differed from his registered name in the local civil registry and contended that his use of the name was a single instance with consent of the real bearer; the demurrer was denied and he appealed to the Supreme Court.
Issues:
- Did petitioner violate C.A. No. 142 as amended by R.A. No. 6085 by introducing himself as "Oscar Perez" at the Office of the Ombudsman?
- Was proof that the alias differed from the registered name in the local civil registry an essential element that the prosecution failed to establish?
Ruling:
The Court reversed and set aside the decisions of the Court of Appeals and the Regional Trial Court and acquitted Petitioner Cesario Ursua of the crime charged. The Court held that the facts showed an isolated, one-time use of another person's name for a limited purpose and did not constitute the habitual or public use of an alias prohibited by C.A. No. 142 as amended by R.A. No. 6085; accordingly, the prosecution failed to prove an offense under that statute.
Ratio:
The Court relied on the statutory purpose of C.A. No. 142, the explanatory history, and precedent, notably Yu Kheng Chiau v. Republic, to define an alias as a name used publicly and habitually in addition to one's real name, usually in business transactions. The singular, isolated use of the name "Oscar Perez" without evidence of intent to be known thereby did not fall within the statute's prohibition; further, penal statutes are construed strictly in favor of the accused, and the legislature's objective to prevent business confusion was absent in the circumstances of this case.
Doctrine:
- An *alias* under C.A. No. 142 as amended by R.A. No. 6085 is a name used publicly and habitually in addition to one's real name.
- (Get Pro to unlock 3 more doctrines)