Ursua v. Court of Appeals

G.R. No. 112170 (April 10, 1996)

Facts:

Petitioner Cesario Ursua was a Community Environment and Natural Resources Officer in Kidapawan, Cotabato. On May 9, 1989, the Provincial Governor of Cotabato requested the Office of the Ombudsman to investigate allegations against Ursua and other officials for bribery, dishonesty, abuse of authority, and providing unwarranted benefits. This complaint stemmed from a resolution by the Sangguniang Panlalawigan of Cotabato, which reported Ursua's involvement in the illegal cutting of mahogany trees and the hauling of illegally-cut logs.

On August 1, 1989, Atty. Francis Palmones, Ursua's counsel, wrote to the Office of the Ombudsman in Davao City requesting a copy of the complaint against Ursua. Due to personal matters concerning his law firm's messenger, Oscar Perez, Ursua was asked to deliver the letter himself. Although Ursua was hesitant to personally request the document because he was a respondent, Perez advised him to use his name if required to acknowledge receipt.

When Ursua arrived at the Ombudsman’s office, he registered in the visitors' logbook under the name "Oscar Perez" and later acknowledged receipt of the complaint using the same name. This action was reported to the Deputy Ombudsman after an acquaintance recognized him and informed the authorities.

On December 18, 1990, after the prosecution presented its evidence, Ursua filed a demurrer to evidence, arguing that the prosecution failed to prove that "Oscar Perez" was an alias different from his registered name. The trial court rejected this argument and found Ursua guilty of violating Section 1 of C.A. No. 142, as amended by R.A. No. 6085, which regulates the use of aliases. He was sentenced to a prison term and fined.

Ursua appealed to the Court of Appeals, which affirmed his conviction but modified the penalty. He subsequently sought a review of his conviction, maintaining his innocence and arguing that he did not use an alias.

Legal Issues:

1. Whether Ursua's use of the name "Oscar Perez" constituted the use of an alias under C.A. No. 142, as amended by R.A. No. 6085.
2. Whether the prosecution met its burden of proving that Ursua's alleged alias was different from his registered name.
3. Whether the trial court and the Court of Appeals erred in their interpretation and application of the law regarding aliases.

Arguments:

• Petitioner’s Arguments:

  • Ursua contended that he did not use an alias, as "Oscar Perez" was not a name he was known by or had used habitually. He argued that an alias implies habitual use, and he only used the name once with Perez's consent.
  • He asserted that the prosecution failed to prove that "Oscar Perez" was different from his registered name, which he claimed was a necessary element for conviction under the law.
  • Ursua also argued that he was charged under the wrong law and that the circumstances of his case did not align with the intent of the statute.

• Respondents’ Arguments:

  • The prosecution maintained that Ursua's actions constituted a violation of the alias law, as he misrepresented himself by using another person's name in an official capacity.
  • They argued that the law was designed to prevent confusion and fraud in business transactions, which Ursua's actions could potentially cause.

Court's Decision and Legal Reasoning:

The Supreme Court reversed the decision of the Court of Appeals and acquitted Ursua. The Court reasoned that the use of the name "Oscar Perez" was not an alias in the context of the law. The Court emphasized that an alias is a name used habitually and publicly in addition to a person's real name. Ursua's use of "Oscar Perez" was isolated and did not indicate an intention to adopt that name as his own.

The Court highlighted that the prosecution did not provide evidence to show that "Oscar Perez" was different from Ursua's registered name, which was a critical element for a conviction under C.A. No. 142. The Court also noted that the act of obtaining a copy of a public complaint did not constitute an offense under the alias law, as the law's intent was to prevent confusion and fraud in business transactions, which was not present in this case.

The Court reiterated the principle that penal statutes should be construed strictly against the state and in favor of the accused, emphasizing the importance of protecting individual rights.

Significant Legal Principles Established:

1. An alias is defined as a name used habitually and publicly in addition to a person's real name, and a single instance of using another person's name does not constitute an alias.
2. The prosecution bears the burden of proving that an alleged alias is different from the accused's registered name for a conviction under C.A. No. 142.
3. Penal statutes must be interpreted strictly in favor of the accused, ensuring that individuals are not convicted under laws that do not clearly apply to their actions.