i can confirm that it didn't used to work this way.. i did a careful test in 10.1.5 (i think -- it was july 2002) showing the file reference was tried first, and if that failed the path was used.. i also noted some bugs in the implementation

i have just checked the Jaguar technote at http://developer.apple.com/technotes/tn2002/tn2053.html and noted the change was documented: "Alias resolution now begins with attempting to resolve the file path name first before attempting to resolve the alias using the file id. This is a fundamental change in the way aliases are resolved and it corrects a problem that would prevent aliases from working as expected on volumes restored from a back up copy. New flags have been added to specify the previous behavior (where the file id would be tried first). Pass kARMTryFileIDFirst to calls which accept a rulesMask or kResolveAliasTryFileIDFirst to calls which accept mountFlags to specify the file id first behavior. (r. 2683228)."

so unfortunately in addressing one problem (perhaps spurred by Dantz & Retrospect, though Retrospect didn't have this problem in Mac OS 9) Apple has created many potential other problems