G.R. No.

5272
US vs Ah Chong (March 19, 2010)

Facts:
Defendant Ah Chong and Pascual Gualderto (deceased) work the same place and are
roommates at “Officers’ quarters No. 27”, which is a detached house some 40meters from the nearest
building. These two servants are the only ones who occupy and sleep in a small room toward the rear
end of this building, the door of which opened upon a narrow porch running along the side of the
building. The porch was covered by thick vines for its entire length and height. The door of the room is
not furnished, and as a means of security, the roommates/occupants, attached a small hook or catch on
the inside of the door, and reinforced this by fastening the door by placing a chair against it.
On the night of August 14, 1908, at about 10:00PM, the defendant was awakened by some
trying to open the door forcefully. He called out twice and asked for the identity, but was not answered.
He was then convinced that it was being pushed open by someone forcing his way into the room, even
considering the fact that prior to this event, there were already cases of robbery in the place. He warned
the intruder “If you enter the room, I will kill you”, but still the person outside was not answering. He
then took a kitchen knife, which he kept under his pillow. When the intruder entered the room, and
before even realizing, because of the darkness, that it’s his roommate, Pascual, the defendant stuck out
wildly with his knife. Upon recognizing that the heavily wounded man was Pascual, the defendant called
out to his employers who slept in the next house and secured bandages to bind up Pascual’s wounds,
who eventually died the next day because of the effects of the wounds. The roommates appear to have
been in friendly and amicable terms prior to the incident, and had an understanding that when either
returned at night, he should knock at the door and acquaint his roommate with his identity. The
defendant alleges that he was keeping a knife under his pillow as a means of protection, as there have
been several cases of robbery prior to the incident. He further admitted to stabbing Pascual with the
contention that he was a robber because he was force-opening their door despite the defendant’s
warnings.
Defendant was found guilty of simple homicide, with extenuating (mitigating) circumstances,
and sentenced to six (6) years and 1 day presidio mayor, the minimum penalty prescribed by law.

Issue:
Is the defendant criminally liable for his acts that night?

Held:
No, he is not criminally liable by reason of mistake of facts. The defendant did an act which he
would be exempt if the facts were as he supposed them to be. It would constitute the crime or
assassination had he known the true state of facts. The mistake of facts was not because of his
negligence or bad faith. The defendant was doing no more than the exercise of his legitimate right to
self-defense. He is not guilty of negligence, recklessness or carelessness in falling into mistake of facts.
RTC then reversed its decision, and the defendant is acquitted.