10/24/2019 Chronicles of a Lost Student: US vs.

AH CHONG

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US vs. AH CHONG
GR. No. L-5272
March 19, 1910

FACTS:

One night, at about 10 o'clock, the defendant was suddenly awakened by someone
trying to force open the door of the room. He sat up in bed and called out twice,
"Who is there?" He heard no answer and was convinced by the noise at the door
that it was being pushed open by someone bent upon forcing his way into the
room.

The room was very dark and the defendant, fearing that the intruder was a robber
or a thief, leaped to his feet and called out. "If you enter the room, I will kill you."
At that moment he was struck just above the knee by the edge of the chair which
had been placed against the door.

In the darkness and confusion the defendant thought that the blow had been
inflicted by the person who had forced the door open, whom he supposed to be a
burglar, though in the light of after events, it is probable that the chair was merely
thrown back into the room by the sudden opening of the door against which it
rested.

eizing a common kitchen knife which he kept under his pillow, the defendant struck
out wildly at the intruder who, it afterwards turned out, was his roommate,
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1) Whether in this jurisdiction one can be held criminally responsible, who, by
reason of a mistake as to the facts, does an act for which he would be exempt from ▼ 2017 (22)
▼
criminal liability if the facts were as he supposed them to be, but which would ▼ October (22)
▼
constitute the crime of homicide or assassination if the actor had known the true INTOD vs CA
state of the facts at the time when he committed the act
PEOPLE vs.
VILLACORTA
2) Whether malice or criminal intent is an essential element or ingredient of the
URBANO vs. IAC
crimes of homicide and assassination as defined and penalized in the Penal Code
LONEY vs. PEOPLE
HELD: US vs. AH CHONG
VILLAREAL VS. PEOPLE
1) The Court holds that under such circumstances there is no criminal liability,
NAVA vs. PALATTAO
provided always that the alleged ignorance or mistake of fact was not due
to negligence or bad faith. In broader terms, ignorance or mistake of fact, if CAUNAN vs. PEOPLE
such ignorance or mistake of fact is sufficient to negative a particular intent which JAVIER vs.
under the law is a necessary ingredient of the offense charged "cancels the SANDIGANBAYAN
presumption of intent," and works an acquittal; except in those cases where the PEOPLE vs. MORILLA
circumstances demand a conviction under the penal provisions touching criminal
DELA CRUZ vs.
negligence; and in cases where, under the provisions of Article 1 of the Penal Code PEOPLE
one voluntarily committing a crime or misdemeanor incurs criminal liability for any
PEOPLE vs.
wrongful act committed by him, even though it be different from that which he ENUMERABLE
intended to commit.
1.0 PRINCIPLES OF
TAXATION 1.1
Nature, scope, clas...

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10/24/2019 Chronicles of a Lost Student: US vs. AH CHONG
2) The definitions of crimes and offenses as set out in the Penal Code rarely contain CPA Board Exam
provisions expressly declaring that malice or criminal intent is an essential PEOPLE vs. ESTRADA
ingredient of the crime, nevertheless, the general provisions of Article 1 of the code
GONZALES vs. ABAYA
clearly indicate that malice, or criminal intent in some form, is an essential
requisite of all crimes and offense therein defined, in the absence of express LADLAD vs. VELASCO
provisions modifying the general rule, such as are those touching liability resulting GEROCHE vs. PEOPLE
from acts negligently or imprudently committed, and acts done by one voluntarily GALVANTE vs.
committing a crime or misdemeanor, where the act committed is different from CASIMIRO
that which he intended to commit.
WHAT IS "EPISTOLARY
JURISDICTION"?
The word "malice" in this article is manifestly substantially equivalent to the words
REPUBLIC ACT 7080
"criminal intent," and the direct inference from its provisions is that the commission (PLUNDER LAW)
of the acts contemplated therein, in the absence of malice (criminal intent),
ESTRADA vs.
negligence, and imprudence, does not impose any criminal liability on the actor. SANDIGANBAYAN

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 Labels
in the mind necessarily relieves the actor from criminal liability provided always
case digest
there is no fault or negligence on his part. "The guilt of the accused must depend
criminal law
on the circumstances as they appear to him."

In this case, the defendant Chinaman struck the fatal blow in the firm belief that Subscribe To

the intruder who forced open the door of his sleeping room was a thief, from whose Posts
assault he was in imminent peril, both of his life and of his property and of the
property committed to his charge; that in view of all the circumstances, as they Comments
must have presented themselves to the defendant at the time, he 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.

*The above case digest is only a guide. I highly recommend that you read the
FULL TEXT.

at October 31, 2017

Labels: ah chong, case digest, crime against persons, criminal law, mistake of fact

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INTOD vs CA

G.R. No. 103119 October 21, 1992 FACTS: At about 10:00 o'clock in the evening,
Petitioner, Mandaya, Pangasian, Tubio and D...

VILLAREAL VS. PEOPLE

ESTRADA vs. SANDIGANBAYAN

WHAT IS "EPISTOLARY JURISDICTION"?

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