US VS AH CHONG

FACTS:
The defendant Ah Chong worked as a cooked while the deceased Pascual
Gilberto who was a house boy. The two of them shared a room having a door with
no permanent lock. As a means of securing it, a chair was placed against the
door. At around 10 in the evening, Ah Chong who was sleeping was awakened by
someone trying to forcefully open the door. He called twice but there was no
response. Fearing that the intruder might be a thief, Ah Chong took his knife and
struck the intruder when it entered the room. It turned out that the said intruder
was his roommate Pascual. Despite his plea of self-defense, said defendant was
found guilty with homicide by the Court of First Instance.

ISSUE:
Whether the defendant by reason of mistake of facts criminally liable.

RULING:
The Court held that there is no criminal liability when one commits an offense or
act due to ignorance of facts provided that it was not due to negligence or bad
faith. Such ignorance of the fact is sufficient to negative the particular intent
which under the law, is an essential element to the crime of murder charged
cancels the presumption of intent and works for an acquittal. In the case, the
defendant struck the fatal blow on the belief that the intruder was a robber, on
which his life and property was in danger. It is clear that he acted in good faith
without negligence and without any criminal intent in exercising his right to self-
defense. There can be no crime, large or small, without an evil mind. The author
of the Penal Code deemed criminal intent or malice to be an essential element of
the various crimes and misdemeanors. It is a principle that the essence of an
offense is the wrongful intent, without which it cannot exist. In other words,
punishment is the sequence of wickedness, without which it cannot be. And
neither in philosophical speculation nor in religious or moral sentiment would
any people in any age allow that a man should be deemed guilty unless his mind
was so. This doctrine confirmed by the maxim actus non facit reum nisi mens sit
rea in which the act itself does not make a man guilty unless his intention were
so. Thus, the Court held that the defendant should be acquitted.