GR L 63817; (August, 1984) (Digest)
G.R. No. L-63817 August 28, 1984
CORAZON LEGAMIA y RIVERA, petitioner, vs. INTERMEDIATE APPELLATE COURT AND PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Corazon Legamia was convicted for violating Commonwealth Act No. 142 , which prohibits the use of an alias name without judicial authority. The information alleged that on or about November 4, 1974, she willfully used the alias “Corazon L. Reyes,” a name different from her registered birth name, Corazon Legamia y Rivera. The trial court sentenced her to imprisonment and a fine, a decision affirmed by the Intermediate Appellate Court.
The factual backdrop reveals that Legamia cohabited with Emilio N. Reyes for 19 years until his death. During this period, she was publicly known as Corazon L. Reyes, was introduced as Mrs. Reyes, and conducted herself as such. After Emilio’s death, she signed a claim for death benefits for their son, Michael, using the name “Corazon L. Reyes.” This act prompted a complaint from Emilio’s legal wife, Felicisima Reyes, leading to the criminal prosecution.
ISSUE
Did the petitioner’s use of the name “Corazon L. Reyes” constitute a violation of Commonwealth Act No. 142 ?
RULING
No. The Supreme Court acquitted petitioner Corazon Legamia. The Court interpreted the law within the context of Philippine societal norms, noting it is a common, though not encouraged, practice for a woman in a live-in relationship to use the surname of her partner. The Court emphasized that the law must be construed in light of the country’s tolerant cultural environment.
The legal logic centered on the absence of a sinister purpose or personal material gain. Legamia used the name “Reyes” openly for nearly two decades as part of her established social identity with Emilio, who himself introduced her as his wife. Her specific act of signing the claim form was to secure benefits for their minor son, an act of guardianship, not one of fraud or deception for her own profit. The Court concluded that the legislature could not have intended to criminalize such conduct under these specific, culturally understood circumstances. The decision of the appellate court was set aside.