G.R. No. 220514 - Oclarino vs. Navarro

Petitioner Cesario Ursua, Community Environment and Natural Resources Officer in Kidapawan, Cotabato, was the subject of a complaint dated May 9, 1989 alleging bribery, dishonesty, abuse of authority, and granting unwarranted benefits in connection with illegal cutting and hauling of mahogany logs.
The Sangguniang Panlalawigan of Cotabato initiated the complaint via resolution, and the Provincial Governor referred it to the Office of the Ombudsman in Manila.

On August 1, 1989 petitioner’s counsel requested a copy of the complaint from the Ombudsman’s Davao office; counsel’s messenger was unavailable, and petitioner was advised to sign the messenger’s name if required.
Petitioner went to the Ombudsman’s office, registered in the visitors’ logbook as “Oscar Perez,” obtained the complaint copy, and acknowledged receipt under that name; the deception was later reported, leading to charges under Sec. 1, C.A. No. 142 as amended by R.A. No. 6085.

Petitioner filed a demurrer to evidence, arguing that the prosecution failed to prove “Oscar Perez” was different from his registered name, but the Regional Trial Court denied the demurrer and convicted him to imprisonment and a fine.
The Court of Appeals affirmed the conviction on May 31, 1993, modified the penalty to an indeterminate term of one to three years and a ₱5,000 fine, prompting petitioner’s appeal to the Supreme Court.

Whether Cesario Ursua’s isolated use of the name “Oscar Perez” amounted to the habitual use of an alias proscribed by Sec. 1 of C.A. No. 142, as amended by R.A. No. 6085.
Whether the prosecution’s failure to present petitioner’s birth registration records vitiated proof of a discrepancy between his real name and the alleged alias.
Whether petitioner was improperly charged under the anti-alias statute when no statutory alias was used.