CESARIO URSUA, petitioner,
COURT OF APPEALS AND PEOPLE OF THE PHILIPPINES, respondents.
Petitioner wrote the name “Oscar Perez” in the visitor’s logbook and used the same in receiving the copy of a complaint against him at the Office of the Ombudsman. This was discovered and reported to the Deputy Ombudsman who recommended that the petitioner be accordingly charged. Trial Court found the petitioner guilty of violating Sec.1 of C.A. No. 142 as amended by R.A. No. 6085 otherwise known as “An Act to Regulate the Use of Aliases“. The Court of Appeals affirmed the conviction with some modification of sentence.
Whether or not the use of alias in isolated transaction falls within the prohibition of Commonwealth Act No. 142.
NO. The questioned decision of the Court of Appeals affirming that of the RTC was reversed and set aside and petitioner was acquitted of the crime charged
[A]n alias is a name or names used by a person or intended to be used by him publicly and habitually usually in business transactions in addition to his real name by which he is registered at birth or baptized the first time or substitute name authorized by a competent authority. A man’s name is simply the sound or sounds by which he is commonly designated by his fellows and by which they distinguish him but sometimes a man is known by several different names and these are known as aliases. Hence, the use of a fictitious name or a different name belonging to another person in a single instance without any sign or indication that the user intends to be known by this name in addition to his real name from that day forth does not fall within the prohibition contained in C.A. No. 142 as amended. This is so in the case at bench.
Time and again [courts] have decreed that statutes are to be construed in the light of the purposes to be achieved and the evils sought to be remedied. Thus in construing a statute the reason for its enactment should be kept in mind and the statute should be construed with reference to the intended scope and purpose. The court may consider the spirit and reason of the statute, where a literal meaning would lead to absurdity, contradiction, injustice, or would defeat the clear purpose of the lawmakers.
While the act of petitioner may be covered by other provisions of law, such does not constitute an offense within the concept of C.A. No. 142 as amended under which he is prosecuted. Moreover, as C.A. No. 142 is a penal statute, it should be construed strictly against the State and in favor of the accused. The reason for this principle is the tenderness of the law for the rights of individuals and the object is to establish a certain rule by conformity to which mankind would be safe, and the discretion of the court limited.