## FACTS:

The petitioner, Cesario Ursua, was a Community Environment and Natural Resources Officer in Kidapawan, Cotabato. He was being investigated for various alleged offenses, including bribery and abuse of authority, based on a complaint filed by the Sangguniang Panlalawigan of Cotabato.

On August 1, 1989, petitioner's counsel requested a copy of the complaint from the Office of the Ombudsman in Davao City. Since his messenger was unavailable, petitioner personally went to the Office of the Ombudsman. Before entering, he discussed with his messenger, Oscar Perez, about how to handle the situation of personally receiving the document as one of the respondents. Perez advised him to use Perez's name if required to acknowledge receipt of the complaint.

When petitioner arrived at the Office of the Ombudsman, he registered in the visitors' logbook using the name "Oscar Perez." He then went to the Administrative Division and handed the letter from his counsel to the Chief, Ms. Loida Kahulugan, who gave him a copy of the complaint. Petitioner acknowledged the receipt by writing the name "Oscar Perez."

During his visit, petitioner encountered an acquaintance, Josefa Amparo, who also worked in the same office. After Amparo learned that the person who introduced himself as "Oscar Perez" was actually petitioner Cesario Ursua, she reported the matter to the Deputy Ombudsman, leading to charges against petitioner.

The trial court found petitioner guilty of violating C.A. No. 142 as amended and imposed a sentence of imprisonment and a fine. On appeal, the Court of Appeals affirmed the conviction but modified the penalty. Petitioner now seeks a review of his conviction, asserting his innocence and contending that he did not use any alias and that the prosecution failed to prove his supposed alias was different from his registered name.

## ISSUES:

1. Whether the petitioner, by using the name "Oscar Perez" in a single isolated transaction, violated Section 1 of C.A. No. 142 as amended by R.A. No. 6085.

## RULING:

The Supreme Court reversed the decision of the Court of Appeals and acquitted the petitioner. The Court held that the use of "Oscar Perez" by the petitioner in an isolated transaction - specifically to retrieve a document from the Office of the Ombudsman - did not constitute the use of an alias as defined and penalized under C.A. No. 142 as amended. The Court noted that the anti-alias law was intended to prevent confusion and fraud especially in business transactions, which were not present in the petitioner's case. The usage by the petitioner of the name "Oscar Perez" did not indicate an intention to habitually or publicly use that name in addition to his real name. Thus, his actions did not fall within the prohibited acts under C.A. No. 142 as amended.

## PRINCIPLES:

1. Statutory Interpretation: Statutes must be construed with regard to the purpose behind their enactment and the evils they are intended to remedy.

2. Strict Construction of Penal Statutes: Penal statutes are to be construed strictly against the State and liberally in favor of the accused. This principle ensures that no individual is penalized under a law unless the text clearly provides for such penalties.

3. Use of Alias: Under C.A. No. 142 as amended, the habitual and public use of a name other than a person’s real or registered name, without judicial authorization and proper recording in the civil registry, is prohibited. An alias involves a name used publicly and habitually usually in business transactions, intended to be used as an additional name by a person.

4. Single and Isolated Use: The single and isolated use of a name, not intended for habitual usage alongside or in place of one’s real name, does not constitute the use of an alias within the meaning of C.A. No. 142 as amended.