Case Brief Assignment – Graphic Organizer

Case Name US v. Ah Chong

Case Citation 15 Phil 488 G.R. No. L-5272
Operative Facts The defendant is a cook in Officers quarters No. 27 in Fort McKinley,
Rizal Province and lodged in a room with Pascual Gualberto,
Clear and brief summary of deceased. On the night of August 14, 1908, at about 10 o’clock, he
relevant facts
was awakened by some force trying to open the door of the room. He
called out but heard no answer and was then convinced that it was
being pushed by a robber or thief and threatened to kill them if the
intruder enters the room. The defendant struck wildly at the intruder
who turns out to be his room mate.
Procedural Facts

How did the action get to the

The case arose out of an appeal of the defendant to the Supreme
current court Court on the ruling of the trial court, wherein he was found guilty of
homicide with extenuating circumstances.

Issue

What is the question being Is the defendant criminally liable for the death of the victim?
presented to the court?

Short Answer/Holding No. Mistake of fact overcomes presumption of malice and

presumption of malice overcomes presumption of voluntariness of the
Court’s answer to the issue act.
Law
The Court cites Article 8 of the Penal Code stating provisions for
What is the rule the court is
using
exemption on criminal liability.

Rationale
How did the court apply the law
to the facts of the case
The Court states that, “in the darkness of the night, in a small room,
with no means of escape, with the thief advancing upon him despite
warnings defendant would have been wholly justified in using any
available weapon to defend himself from such an assault, and in
striking promptly, without waiting for the thief to discover his
whereabouts and deliver the first blow”. In addition to this, the legal
maxims “the act itself does not make man guilty unless his intention
were so” was applied. The defendant is legally guiltless of the
homicide for “notwithstanding some decisions apparently adverse,
whenever a man undertakes self-defense, he is justified in acting on
the facts as they appear to him”. The decision of the trial court was
reversed.