PERSONS & FAMILY

TOPIC: Article 3 - Ignorance of the law excuses no one from compliance therewith.
Ignorance or mistake in point of fact is, in all cases of supposed offense, a sufficient excuse

TITLE: US v. Ah Chong
G.R. No. L-5272             March 19, 1910
PLAINTIFF: The United States
DEFENDANT: Ah Chong
PONENTE: Carson, J.

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. And due to the heavy growth of vines along the
front of the porch, the room was very dark

At around 10 in the evening, Ah Chong who was sleeping was awakened by someone trying
to forcefully open the door. He called twice asking who it was but there was no response.
He then warned the intruder that he entered the room, Ah Chong will kill him.

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 In-
stance.

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

RULING:
NO. 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.

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 PERSONS & FAMILY

There is no technical rule, and no pressing necessity therefore, requiring mistake in fact to be
dealt with otherwise that in strict accord with the principles of abstract justice. On the contrary,
the maxim here is Ignorantia facti excusat

Since evil intent is in general an inseparable element in every crime, any such mistake of fact as
shows the act committed to have proceeded from no sort of evil in the mind necessarily relieves
the actor from criminal liability provided always there is no fault or negligence on his part

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.

MAXIM: There can be no crime, large or small, without an evil mind.

Ignorantia facti excusat, - ignorance or mistake in point of fact is, in all cases of supposed of-
fense, a sufficient excuse
Ignorantia juris non excusat - Ignorance of the law excuses no man

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