People vs.

Oanis

1. WON Oanis and Galanta incur no liability due to innocent mistake of fact in the
honest performance of their official duties.

July 27, 1943 (74 Phil 257)

2. WON Oanis and Galanta incur no criminal liability in the performance of their duty.
PARTIES:
HELD:
Plaintiff and appellee: People of the Philippines
Defendants and appellant: Antonio Oanis, Alberto Galanta
FACTS:
Antonio Oanis and Alberto Galanta were instructed to arrest a notorious criminal and
escaped convict, Anselmo Balagtas, and if overpowered, to get him dead or alive.
They went to the suspected house then proceeded to the room where they saw the
supposedly Balagtas sleeping with his back towards the door. Oanis and Galanta
simultaneously or successively fired at him which resulted to the victims death. The
supposedly Balagtas turned out to be Serepio Tecson, an innocent man.

ISSUE:

1. No. Innocent mistake of fact does not apply to the case at bar. Ignorance facti
excusat applies only when the mistake is committed without fault or carelessness.
The fact that the supposedly suspect was sleeping, Oanis and Galanta could have
checked whether it is the real Balagtas.
2. No. Oanis and Galanta are criminally liable. A person incurs no criminal liability
when he acts in the fulfillment of a duty or in the lawful exercise of a right or office.
There are 2 requisites to justify this: (1) the offender acted in teh perfomance of a
duty or in the lawful exercise of a right or office, (2) that the injury or offense
committed be the necessary consequence of the due performance of such duty or
the lawful exercise of such right or office. In this case, only the first requisite is
present.