Has been like this for as long as I can remember (at least back to IE6).
e.g:
<input name="test">
<div id="test">
document.getElementById('test'); // <input> in IE6
I believe this also wound up in some Webkit and Opera releases, perhaps for emulation. Someone more knowledgeable about it all should feel free to correct me if I'm wrong though.(Edited for code formatting, I don't comment too much these days)