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

Case Summary (G.R. No. L-63817)

Procedural History and Key Dates

Period of cohabitation: Corazon lived with Emilio from November 8, 1955 to September 26, 1974.
Child’s birth: Michael born October 18, 1971.
Claim and payment: Corazon filed a death-benefits claim on October 29, 1974; payment voucher signed “Corazon L. Reyes.”
Criminal accusation: Information charged Corazon with using an alias (Commonwealth Act No. 142, as amended) discovered on or about November 4, 1974.
Trial court: Convicted Corazon, imposing an indeterminate sentence of one (1) to two (2) years, fine of P5,000 and costs; recommended executive clemency.
Intermediate Appellate Court: Affirmed the conviction in toto.
Supreme Court decision date: August 28, 1984 (appeal by certiorari).

Applicable Legal Framework

Primary statutory provision: Commonwealth Act No. 142, Section 1 (as amended by R.A. No. 6085), which generally proscribes the use of any name different from the one registered at birth, baptized name, or court-authorized substitute name, except for limited pseudonymous uses (literary, entertainment, athletics). Constitutional basis: the 1973 Philippine Constitution governed at the time of the decision.

Charged Offense and Information Allegations

Corazon was charged for willfully and unlawfully using the substitute or alias name “CORAZON L. REYES,” different from her registered name “Corazon Legamia y Rivera,” without prior court authorization and not as a permitted pseudonym. The information alleged such use occurred on or about November 4, 1974 and for some time prior and subsequent thereto.

Factual Findings Relevant to the Offense

Long-term cohabitation: Corazon and Emilio lived together for nearly 20 years and publicly presented themselves in a marital relationship.
Public representation: Corazon styled herself and was introduced by Emilio as “Mrs. Reyes” and regularly used the surname “Reyes.”
Purpose of name use: The record shows Corazon signed the claim for death benefits and the payment voucher for their son Michael as “Corazon L. Reyes”; the claim was pursued on behalf of the child, not for personal gain.
Complaining party: Felicisima Reyes, Emilio’s lawful spouse, initiated the complaint upon discovering use of the Reyes name.

Trial and Appellate Disposition

The trial court found Corazon guilty and imposed imprisonment, fine, and costs but recommended clemency. The Intermediate Appellate Court affirmed that conviction and sentence in full, prompting the petition for certiorari to the Supreme Court.

Issue Presented

Whether petitioner Corazon Legamia violated Commonwealth Act No. 142 by using the surname “Reyes” despite not being legally married to Emilio and without court authorization.

Supreme Court’s Analysis and Reasoning

The Court grounded its analysis in social and factual context rather than a purely literal application of the statute. It observed that, in Philippine society, it is a common practice for a woman who cohabits with a man to present herself as his wife and to adopt his surname, even when the man is legally married to another. While the practice is discouraged, the Court noted societal tolerance and the prevalence of the conduct, implying that the statute should be construed with regard to such cultural realities.

Applying the facts, the Court emphasized Corazon’s long period of cohabitation with Emilio (almost twenty years), her public assumption of the marital role and surname without evidence of sinister intent or personal material gain, and that the conte

Case Syllabus (G.R. No. L-63817)

Citation and Court

Reported at 216 Phil. 447, Second Division.
G.R. No. L-63817.
Decision date: August 28, 1984.
Opinion authored by Justice Abad Santos.
Concurrences: Justices Concepcion, Jr., Escolin, and Cuevas concurred.
Justices Makasiar (Chairman) and Guerrero were on official leave.
Justice Aquino concurred with a special note emphasizing protection of the son and cautioning against encouraging the practice of common-law naming.

Procedural Posture

The case is an appeal by certiorari to review and reverse a decision of the Intermediate Appellate Court.
The petitioner, Corazon Legamia y Rivera, was originally charged and convicted in the defunct Court of First Instance of Manila for using an alias in violation of Commonwealth Act No. 142, as amended.
The trial court sentenced the petitioner and recommended she be extended executive clemency.
The Intermediate Appellate Court affirmed the trial court's conviction and sentence in toto.
The present proceeding is the petition for review to the Supreme Court.

Information (Criminal Charge Allegation)

The information charged that on or about November 4, 1974, and for some time prior and subsequent thereto, in the City of Manila, the accused willfully and unlawfully used the substitute or alias name "CORAZON L. REYES."
The information alleged that this name was different from "Corazon Legamia y Rivera" with which she was christened or known since childhood.
It stated the use was not as a pseudonym for literary purpose and was without prior court authorization.
The discovery of the alleged use was averred to be on or about November 4, 1974. (Rollo, pp. 11-12.)

Facts — Personal and Domestic Circumstances

Corazon Legamia lived with Emilio N. Reyes for 19 years, from November 8, 1955 to September 26, 1974, the date of Emilio’s death.
During their live-in relationship they had a son, Michael Raphael Gabriel L. Reyes, born October 18, 1971.
Throughout the cohabitation, Corazon was known as "Corazon L. Reyes"; she styled herself as Mrs. Reyes and was introduced by Emilio to friends as Mrs. Reyes.
Emilio N. Reyes held the position of Branch Claim Manager, Naga Branch, of the Agricultural Credit Administration at the time of his death.
On or shortly after October 29, 1974, Corazon filed a letter claim with the Agricultural Credit Administration for death benefits on behalf of her son Michael; the letter was signed "Corazon L. Reyes."
The voucher evidencing payment of Michael’s claim in the amount of P2,648.76 was also signed "Corazon L. Reyes."
The payment to Michael was described as "equivalent to 2/5 of that which is due to each legitimate child in accordance with the provisions of the Civil Code," per advice given by Atty. Diomedes A. Bragado of the Agricultural Credit Administration.
Felicisima Reyes, who was married to Emilio, filed a complaint leading to Corazon’s prosecution for using the name Reyes though she was