Cesario Ursua Vs Court of Appeals

Ursua vs Court of Appeals (1996)
Summary Cases:
● Cesario Ursua vs Court of Appeals
Subject:
Anti-Alias Law; Statutory Construction (Ratio Legis Est Anima); Statutory Construction (Penal Statutes)
Facts:
Cesario Ursua was charged with violation of Sec. 1 of C.A. No. 142, as amended by RA 6085, otherwise
known as "An Act to Regulate the Use of Aliases.”
Ursua, an environmental officer, together with others, were being investigated before the Ombudsman
regarding their involvement in the illegal cutting of mahogany trees and hauling of illegally-cut logs in the
Cotobato area.
Atty. Francis Palmones, counsel for petitioner, wrote the Office of the Ombudsman requesting that he be
furnished copy of the complaint against petitioner Ursua. Atty. Palmones then asked his client Ursua to
take his letter-request to the Office of the Ombudsman because his law firm's messenger, Oscar Perez,
had to attend to some personal matters. Ursua talked to Oscar Perez and told him that he was reluctant
to personally ask for the document since he was one of the respondents before the Ombudsman.
However, Perez advised him not to worry as he could just sign his (Perez) name if ever he would be
required to acknowledge receipt of the complaint.
When Ursua visited the Office of the Ombudsman, he signed the name “Oscar Perez” in the visitor
logbook and when acknowledging receipt of the copy of complaint.
When administrative officer Loida Kahulugan learned through a co-worker (who was also an
acquaintance of Ursua) that the person who introduced himself as "Oscar Perez" was actually petitioner
Cesario Ursua, she reported the same which led to the present charges being filed.
The trial court found Ursua guilty of violating the Anti-Alias Law which conviction was affirmed in the
Court of Appeals. Hence, this petition.
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Held:
Use of Alias
1. An 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.
2. 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.
3. 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.
4. The use of the name "Oscar Perez" was made by petitioner in an isolated transaction where he was
not even legally required to expose his real identity. Even if Ursua used a false name, he would still be
entitled to obtain a copy of the complaint which is part of the public records. Also, there is no evidence
showing that he had used or was intending to use that name as his second name in addition to his real
name.
Statutory Construction (Ratio Legis Est Anima)
5. 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.
6. The enactment of C.A. No. 142 was made primarily to curb the common practice among the Chinese
of adopting scores of different names and aliases which created tremendous confusion in the field of
trade. Such a practice almost bordered on the crime of using fictitious names which for obvious reasons
could not be successfully maintained against the Chinese who, rightly or wrongly, claimed they
possessed a thousand and one names. C.A. No. 142 thus penalized the act of using an alias name,
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unless such alias was duly authorized by proper judicial proceedings and recorded in the civil register.
Statutory Construction (Penal Statutes)
7. 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.
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Cesario Ursua Vs Court of Appeals

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Ursua vs Court of Appeals (1996)

● Cesario Ursua vs Court of Appeals

Statutory Construction (Ratio Legis Est Anima)

Statutory Construction (Penal Statutes)

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