People v.

Oanis (1943)
Plaintiff Appellee: The People of the Philippines
Defendant Appellants: Antonio Z. Oanis, Alberto Galanta
Definition of Felony

Summary: Police officers mistakenly kill an innocent man for a notorious criminal
Facts:



On December 24, 1938 the defendants were shown a telegram to capture a
wanted criminal – Anselmo Balagtas.
o The telegram instructed that if they are overpowered, they should get
Balagtas dead or alive.
Oanis was asked by the chief of police if he knew one Irene (a ballerina).
Oanis said he knew someone of loose morals who has the same name.
They went to the house where this Irene was supposedly living.
o They then asked a resident of that area where the room of Irene was.
The resident pointed the place and said that Irene was with her
paramour.
o The Defendant Appellants went to Irene’s room.
 They saw a man sleeping with his back to the door, and
simultaneously or successively fired at him with their .32 and .
45 caliber revolvers.
 Irene was awoken by the shots and she saw that her paramour
was wounded and was still being fired at.
 Turns out it wasn’t Anselmo Balagtas but a Serapio Tecson.
 The Provincial Inspector, who was with them, asked who did the
deed and the defendants admitted to commiting the act.
Defendant appellants had their own versions but was rejected.
o It contradicted the evidence and testimony of Irene.
It was contended that Defendant-Appellants made an innocent mistake in the
performance of their duties. The lower court declared them guilty of homicide
through reckless imprudence.

Issue:
WoN Defendant-Appellants are responsible for the death of Serapio Tecson?
Yes
o

The decision in US v. Ah Chong (ignorantia facti excusa) is not applicable.
 In this case, the appellants had ample time to ascertain the
identity of the person asleep. In addition, he was also unarmed.
They had no reason for immediate action. The mistake is with
fault and carelessness

o

o
o

Rules of Court thus: "No unnecessary or unreasonable force shall be
used in making an arrest, and the person arrested shall not be subject
to any greater restraint than is necessary for his detention."
 Even if Balagtas was a notorious criminal, that does not justify
the excess use of force or unnecessary violence.
The crime committed by appellants is not merely criminal negligence,
the killing being intentional and not accidental.
Revised Penal Code Article 11, No.5 (Criminal Liability)
 The offender acted in the performance of a duty or in the lawful
exercise of a right [PRESENT]
 The injury or offense committed be the necessary consequence
of such duty or the lawful exercise of such right [NOT PRESENT –
their duty was to arrest or capture; dead or alive if resistance is
offered by him and they are overpowered]