US vs.

Ah Chong

Lagangang Butas Criminal Law, LAW, Selected Case Digests January 3, 2013 1 Minute

US vs. Ah Chong
G.R. No. L-5272. March 19, 1910

Plaintiff-appelle: The United States

Defendant-appellant: Ah Chong
Ponente: J. Carson

FACTS:
The accused, Ah Chong, was employed as a cook in Fort Mckinley and was sharing the house with the
deceased, Pascual Gualberto, who was employed as a house boy. The door of the room they were
occupying was not furnished with a permanent lock, and as a measure of security, they fasten the door
by propping a chair against it. One evening, Ah Chong was suddenly awakened by someone trying to
force open the door of their room. The deceased and the accused had an understanding that when
either returned late at night, he should knock at the door and acquaint his companion with his identity.
Ah Chong sat up in bed and called out twice, Who is there? but heard no answer. The room was quite
dark, and as there had been recent robberies in Fort McKinley, fearing that the intruder was a robber or
a thief, he leaped to his feet and called out. If you enter the room, I will kill you. Suddenly, he was
struck by the edge of the chair which had been placed against the door. Believing that he was being
attacked, he seized a common kitchen knife which he kept under his pillow and wildly struck and fatally
wounded the intruder who turned out to be his roommate, Pascual.

ISSUE:
Whether or not the accused was criminally liable.

HELD:
No. The rule is that one is not criminally liable if he acted without malice (criminal intent), negligence,
and imprudence. In the present case, the accused acted in good faith, without malice or criminal intent,
in the belief that he was doing no more than exercising his legitimate right of self-defense. Had the facts
been as he believed them to be, he would have been wholly exempt from criminal liability on account of
his act. Moreover, the accused cannot be said to have been negligent or reckless as the facts as he saw
them threatens his person and his property. Under such circumstances, there is no criminal liability, as
the ignorance or mistake of fact was not due to negligence or bad faith.