THE UNITED STATES vs AH CHONG

FACTS:

>Ah Chong (a cook) and Pascual Gualberto (a muchacho) both lived in Officers Quarter 27 in Fort
McKinley, Rizal Province.

>There have been several robberies in the Fort, thats why Ah Chong keeps a knife under his pillow and
also since their door is not permanently bolted, they attach it with a hook and place it against a chair.

>Description of the physical situation (furnitures, etc) to give credence to partys statements.

>All the circumstances of the room will make him believe that he is under attack, mistake of fact.

>Ah Chong was described a simple minded person, and yet the physical surroundings around him fit
perfectly with his statements. That is why the court believed him to tell the truth.

>Both of them were on friendly-terms and for security reasons they both had an understanding that
should either return to the room at night, he should knock and inform the roommate with his identiy.

>On Aug 14, 1908 at 10pm, Ah Chong was suddenly awakened by someone trying to open the door with
brute force. The room was very dark as the vines have significantly grown outside their door at the
porch.

>Ah Chong thinking this guy might most likely be a robber. Ah Chong called out twice to identify himself,
to no avail. He also shouted If you enter the room, I will kill you! still no answer. At that same time, Ah
Chong was struck by his knee, then Ah Chong knows that the intruder has already forced the door
open. To protect himself, his properties and other properties under his care, he took out his knife and
stuck the intruder.

>In light of events, the intruder was actually Pascual. Seeing him severely wounded, Ah Chong ran out to
his employers to secure bandages for Pascuals wound. The following day he died in a military hospital.

>Trial court initially found him guilty of simple homicide with extenuating circumstances and 6 years
sentence and 1 day presidio mayor.t

ISSUE:

Whether or not Ah Chong is held criminally liable for Pascuals death?

Whether in this jurisdiction one can be held criminally responsible who by a mistake of facts, does an act
which he would be exempted from criminal liability, but constitutes a crime, if one had known the true
state of the facts upon commission of the act.

HELD:

>Ignorance of mistake of fact is sufficient to negative/cancel an intent (criminal intent) which under law
is a necessary ingredient of a crime.

>Article 8 of Penal Code: lists exemptions from criminal liability

1. Illegal aggression
 2. Reasonable necessity of the means employed

3. Lack of sufficient provocation on the person defending himself.

>Article 1 of Penal Code, defines crimes as voluntary acts and omissions punished by law.

>Voluntary act is free, intelligent and intentional

>Intent here is equivalent to malice

>Bishop: There can be no crime without an evil mind.

The essence of an offense is a wrongful intent.

The act itself does not make man guilty unless his intentions were so.

>Baron Parke: Whenever a man undertakes self-defense, he is justified in action on the facts as they
appear to him.

>>>Judgment by the trial court should be reversed and defendant be acquitted of his crime.

Judicial Precedence given by Supreme Court. Parties that go through the same situations as the previous
case, this should be followed.