BatchPlay: Select layer doesn't work when multiple layers have the same name

Found a solution. It seems to be possible to also pass the ID in the target object. The solution was to refer to the id property instead of the name property:

const batchPlay = require("photoshop").action.batchPlay;
const result = batchPlay(
[
   {
      "_obj": "select",
      "_target": [{ "_ref": "layer", "_id": 3}],
      "makeVisible": false,
      "layerID": [3],
      "_isCommand": false,
      "_options": {"dialogOptions": "dontDisplay"}
   }
],{ "synchronousExecution": false, "modalBehavior": "fail"});