PEOPLE OF THE PHILIPPINES VS.

OANIS

July 27, 1943
G.R. No. 47722

PARAS

PRINCIPLES INVOLVED: Mistake of Fact

RELEVANT LAWS CITED: Article 3

FACTS:

As a group taking the route to Rizal street, Chief of Police Antonio Z. Oanis and his co-accused
Corporal Alberto Galanta were under instructions to arrest Anselmo Balagtas, a notorious
criminal and escaped convict, and if overpowered, to get him dead or alive. Proceeding to the
suspected house, they went into a room and on seeing a man sleeping with his back towards the
door, simultaneously fired at him with their .32 and .45 caliber revolvers, without first making
any reasonable inquiry as to his identity. The victim turned out to be a peaceful and innocent
citizen, Serapio Tecson who upon autopsy, multiple gunshot wounds were found on his body
which caused his death.

ISSUE:

I. Whether or Not Mistake of Fact can be used as a valid defense of the Police Officers.

RULING:

No. According to the law, the elements of mistake of fact are that the act done would have been
lawful had the facts been as the accused believed them to be, that the intention of the accused in
performing the act should be lawful and that the mistake must be without fault or carelessness on
the part of the accused. In the case, the defendants were unable to practice prudence and extra
care. Therefore, Mistake of Fact is not a valid defense.