Ursua v.

CA
G.R. No. 112170, April 10, 1996
Legislative intent; spirit and reason

Held: NO.

Petitioner: Cesario Ursua

Respondent: CA

Ratio: Ursua claims that he has never used an alias before. Alias is a term
which connotes the habitual use of another name by which one is also known.
He is not known as Oscar Perez. He only used that name on one occasion
with express consent by Oscar Perez himself.

Facts: Ursua is a Community Environment and Natural Resources Officer,

stationed in Cotabato. The Provincial Governor requested Ombudsman to
investigate a complaint for bribery, dishonesty, abuse of authority by
petitioner on the ground of illegal logging. Ursuas counsel requested for a
copy of the complaint. Counsel then asked Ursua to get the copy because his
law firm messenger, Oscar Perez was busy attending to personal matters.
Ursua was reluctant to get it because it was a complaint against him, but
Oscar Perez assured Ursua that he could just sign in Perez name. Ursua did
just that, and before he was about to leave the Ombudsman, he ran into an old
acquaintance who recognised him.
He was subsequently charged for wrongful use of alias. Ursua filed a
demurrer to evidence on the ground that prosecution was unable to prove that
his supposed alias was different than his registered name in the local civil
registry. He argued that no evidence was presented from the civil registry
which is a requirement sine qua non to his conviction.
RTC Ruling: He was found guilty of violating CA No. 142 as amended by
RA No. 6085 (Alias Regulation Law).
CA Ruling: Ursua appealed to CA which just modified his penalties.
Issue: W/N Ursua is guilty under the charges against him?

BASIC STATCON RULE: Statues are to be construed in the light of the

purpose to be achieved, and evil to be remedied. Court may then consider the
spirit and reason of the statute if direct interpretation leads to absurdity,
contradiction, injustice, or would defeat the purpose of the lawmakers.
The basis for the law was because Chinese merchants use various names
during business transactions that caused tremendous confusion in the trade.
Yu Kheng Chiau v. PP SC held not to grant petitioners request for alias
because it would add to more confusion.
Clearly, alias is habitually used for business transaction. That Ursua used
Oscar Perez to pick up the copy of his complaint at the Ombudsman does not
warrant his conviction under CA No. 142 because this was a one time
occurrence and evidence does not prove that he intends to use Perez as his
alias.
Moreover, CA No. 142 is a penal statute. It should be construed strictly
against the State and in favour of the accused. Ursua should not be convicted
of a law that does not clearly penalise the act done by him.