Facts: Limson filed a case for falsification against Eugenio Juan Gonzalez. Limson asserted that in the records of the Professional Regulatory Commission (PRC), a certain ‘EUGENIO GONZALEZ’ is registered as an architect and that Gonzalez, who uses, among others, the name ‘EUGENIO JUAN GONZALEZ’, pretends to be said architect. Gonzalez is an impostor and therefore, guilty of falsification.
Gonzalez filed his Counter–Affidavit, wherein he explained in detail that his full name is EUGENIO JUAN GONZALES y REGALADO. He alleges that in grade school and high school, he used the name EUGENIO GONZALEZ y REGALADO and/or EUGENIO GONZALEZ but when he transferred to the University of Sto. Tomas and took up Architecture, he made use of his second name, JUAN after EUGENIO. After he passed the board exam, he made use as much as possible the name Arch. Eugenio Juan Gonzalez, because the surname GONZALEZ was and is still, a very common surname throughout the Philippines and he wanted to distinguish himself.
After weighing the evidence, the investigating prosecutor dismissed the case. Limson appealed to the Secretary of Justice who affirmed the findings of the prosecutor.
Limson then filed a new letter complaint against Gonzalez with the Secretary of Justice, alleging the same accusations, this time for violation of the Anti-Alias Law. The DOJ referred to the Office of the City Prosecutor of Mandaluyong City and docketed as a new case. Even so, the Prosecutor’s Office dismissed the new case.
When her case met the same fate, Limson again filed a petition for review with the DOJ, which again denied her petition. The CA affirmed the decision of the DOJ.
In her petition for review on certiorari filed with the Supreme Court, Limson insists that the names “Eugenio Gonzalez” and “Eugenio Juan Gonzalez y Regalado” did not refer to one and the same individual; and that respondent Gonzalez was not a registered architect contrary to his claim. According to her, there were material discrepancies between the graduation photograph of respondent taken in 1941 when he earned his degree in Architecture from the University of Sto. Tomas, Manila, and another photograph of him taken for his driver’s license in 1996, arguing that the person in the latter photograph was not the same individual depicted in the 1941 photograph. She submits documents showing that respondent used aliases from birth, and passed himself off as such persons when in fact he was not.
Held: The Supreme Court held that it is not a trier of facts, and cannot analyze and weigh evidence.
It also held that Limson did not persuasively demonstrate to the CA how the Secretary of Justice had been gravely wrong in upholding the dismissal by the OCP of her charges against respondent. In contrast, the assailed resolutions of the Secretary of Justice were quite exhaustive in their exposition of the reasons for the dismissal of the charges. And, even assuming that the Secretary of Justice thereby erred, she should have shown to the CA that either arbitrariness or capriciousness or whimsicality had tainted the error. Yet, she tendered no such showing. She should be reminded, indeed, that grave abuse of discretion meant either that the judicial or quasi–judicial power was exercised by the Secretary of Justice in an arbitrary or despotic manner by reason of passion or personal hostility, or that the Secretary of Justice evaded a positive duty, or virtually refused to perform the duty enjoined or to act in contemplation of law, such as when the Secretary of Justice, while exercising judicial or quasi–judicial powers, acted in a capricious or whimsical manner as to be equivalent to lack of jurisdiction.
On the issue of the alleged use of illegal aliases, the court held that respondent’s aliases involved the names “Eugenio Gonzalez”, “Eugenio Gonzales”, “Eugenio Juan Gonzalez”, “Eugenio Juan Gonzalez y Regalado”, “Eugenio C.R. Gonzalez”, “Eugenio J. Gonzalez”, and – per Limson – “Eugenio Juan Robles Gonzalez.” But these names contained his true names, albeit at times joined with an erroneous middle or second name, or a misspelled family name in one instance. The records disclose that the erroneous middle or second names, or the misspelling of the family name resulted from error or inadvertence left unchecked and unrectified over time. What is significant, however, is that such names were not fictitious names within the purview of the Anti–Alias Law; and that such names were not different from each other. Considering that he was not also shown to have used the names for unscrupulous purposes, or to deceive or confuse the public, the dismissal of the charge against him was justified in fact and in law.
It also held that Limson did not persuasively demonstrate to the CA how the Secretary of Justice had been gravely wrong in upholding the dismissal by the OCP of her charges against respondent. In contrast, the assailed resolutions of the Secretary of Justice were quite exhaustive in their exposition of the reasons for the dismissal of the charges. And, even assuming that the Secretary of Justice thereby erred, she should have shown to the CA that either arbitrariness or capriciousness or whimsicality had tainted the error. Yet, she tendered no such showing. She should be reminded, indeed, that grave abuse of discretion meant either that the judicial or quasi–judicial power was exercised by the Secretary of Justice in an arbitrary or despotic manner by reason of passion or personal hostility, or that the Secretary of Justice evaded a positive duty, or virtually refused to perform the duty enjoined or to act in contemplation of law, such as when the Secretary of Justice, while exercising judicial or quasi–judicial powers, acted in a capricious or whimsical manner as to be equivalent to lack of jurisdiction.
On the issue of the alleged use of illegal aliases, the court held that respondent’s aliases involved the names “Eugenio Gonzalez”, “Eugenio Gonzales”, “Eugenio Juan Gonzalez”, “Eugenio Juan Gonzalez y Regalado”, “Eugenio C.R. Gonzalez”, “Eugenio J. Gonzalez”, and – per Limson – “Eugenio Juan Robles Gonzalez.” But these names contained his true names, albeit at times joined with an erroneous middle or second name, or a misspelled family name in one instance. The records disclose that the erroneous middle or second names, or the misspelling of the family name resulted from error or inadvertence left unchecked and unrectified over time. What is significant, however, is that such names were not fictitious names within the purview of the Anti–Alias Law; and that such names were not different from each other. Considering that he was not also shown to have used the names for unscrupulous purposes, or to deceive or confuse the public, the dismissal of the charge against him was justified in fact and in law.
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 the real name by which he was registered at birth or baptized the first time, or to the 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. An alias is thus a name that is different from the individual’s true name, and does not refer to a name that is not different from his true name." (Limson vs. Gonzalez, G.R. No. 162205, March 31, 2014)
