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.