"But that's subjecting the user to limitations of the system!" you might object, and while you'd be right we should also ponder whether a filesystem is a word processor or a system for locating data using filenames as identifiers, and consequently, what sound handling of identifiers is.
And let's be realistic. Most users will choose the file to open from a file picker dialog. fopen() is not their interface, their interface is a file picker.
The intersection of people for whom fopen() is their interface (no file pickers) but for whom learning lessons on the value of using unambiguous identifiers is somehow out of reach, would be exceedingly small.