U.S. vs.

Ah Chong

G.R. No. L-7929 March 19, 1910

Facts: Because of the many bad elements happening at Fort McKinley, Ah Chong,
a cook, locked himself in his room by placing a chair against the door. After having
gone to bed, he was awakened by someone trying to open the door of his room.
He called out twice, “Who is there,” but received no answer. Fearing that the
intruder was a robber, he leaped from his bed and called out again, “If you enter
the room I will kill you.” But at the precise moment, he was struck by the chair
and believing that he was being attacked, he seized a kitchen knife and struck and
fatally wounded the intruder who turned out to be his roommate.

Issue: Whether or not Ah Chong was guilty of murder.

Ruling: Under Article 11 paragraph 1 of the Revised Penal Code provides

that to justify the act, there should be:

First. Unlawful aggression on the part of the person killed;

Second. Reasonable necessity of the means employed to prevent or repel

it;

Third. Lack of sufficient provocation on the part of the person defending

himself.

Ah Chong was not held liable for the death of his roommate. The Supreme
Court reversed the lower court’s conviction of homicide, saying that Ah
Chong committed a mistake of fact. He would not have stabbed his
roommate had he known the identity of the person who entered the room. If
the person who opened the door had really been a robber instead of his
roommate, he would not be criminally liable if he had stabbed that person
in self-defense.