US v. Ah Chong GR No. L-5272, March 19, 1910 Facts: The defendant, Ah Chong, was employed as a cook in one of the Officers’ quarters at Fort McKinley, Rizal Province. Together living with him in the said quarters was the deceased, Pascual Gualberto, who was employed as a houseboy. There had been several robberies in Fort McKinley prior to the incident thus prompting the defendant and his roommate to reinforce the flimsy hook used to lock the door of their room by placing a chair against it. The defendant and the deceased had an understanding that when either returned at night, he should knock on the door and say his name. On the night of Aug. 14, 1908, Ah Chong, who was alone in his room, was awakened by someone trying to force open the door of the room. The defendant called out twice, asking the identity of the person but heard no answer. Fearing that the intruder was a robber or a thief, the defendant called out that he would kill the intruder if he tried to enter. At that moment, the door was forced open and the defendant was struck first above the knee by the edge of the chair. Because of the darkness of the room, the defendant thought he was being hit by the intruder and tried to defend himself by striking wildly at the intruder using a common kitchen knife which he kept under his pillow. It turned out that the said intruder was actually the defendant’s roommate, Pascual Gualberto. The roommate was brought to the military hospital where he died from the effects of the wound the following day.
Issue: WON the defendant was criminally liable for committing a felony. Held: Defendant was not criminally liable and exonerated. In order for mistake of fact to be held as a valid defense, there has to be several requisites. One, that the act done would have been lawful had the facts been as the accused believed them to be. Two, that the intention of the accused in performing the act should be lawful, and lastly, that the mistake must be without fault or carelessness on the part of the accused. In the case at bar, had the intruder been a robber as the defendant believed him to be, then Ah Chong acted in good faith, without malice or criminal intent, and would have been wholly exempt from criminal liability and that he cannot be said to have been guilty of negligence or recklessness.
