UNITED STATES VS. AH CHONG FACTS: August 14, 1908, Ah Chong, a cook employed at Officers Quarters, No.

27 was awakened at night by a knock on the door. He called and asked who it was but there came no reply. He leapt from his bed and approached the door. The door was forced closed by only a chair and the room was dark due to some heavy vines by the window. Defendant warned the person that should he enter he will kill him. Ah Chong was then struck just above the knee, thinking it was his attacker, a supposed burglar, he struck out wildly against the man killing him. The man was Pascual, his roommate. After seeing this, the defendant rushed to house no. 28 to call for help and then ran back to his room to secure bandages and bind up Pascuals wounds. Pascual died the following day. Ah Chong was charged of simple homicide. Defendant insists that he struck the fatal blow without any intent to do a wrongful act as it is in exercise of his lawful right to self-defense. ISSUE: WON a person can be held criminally responsible for an act, which was done by mistake of fact without bad faith? HELD: NO. There is no criminal liability, provided that the ignorance or mistake of fact was not due to negligence or bad faith. The defendant was acquitted of th crime. RATIO: Ah Chong was possessed by the fear of recent string of burglaries that have occurred in their area and the kitchen knife in the room that he shared with Pascual was for self-defense. The defendant took necessary precautions by asking who it was that was knocking at the door but no answer came. Also, the defendant believed he was under attack when the chair, propped up against the door, hit him above the knee. His actions were done in complete self-defense as he was not aware of who the person was as the room was completely dark.

LIBI VS. IAC FACTS: Julie Ann Gotiong and Wendell Libi were a sweetheart until the former broke up with the latter after she found out the Wendell was irresponsible and sadistic. Wendell wanted reconciliation but was not granted by Julie so it prompted him to resort to threats. One day, there were found dead from a single gunshot wound each coming from the same gun. Julie Anns parents then filed a civil case against the Libis for damages brought about by the actions of their son. The Libis are now petitioning that they are not to be held liable for damages. ISSUE: WON the parents should be held liable for such damages. HELD: YES. The civil liability of the parents for crimes committed by their minor children is likewise direct and primary, and also subject to the defense of lack of fault or negligence on their part and that they practiced diligence of a good father of a family. Petition was denied. RATIO: The subsidiary liability of parents for damages caused by their minor children imposed under Art 2180 of the Civil Code and Art. 101 of Revised Penal Code covered obligations arising from both quasi-delicts and criminal offenses. The court held that the civil liability of the parents for quasidelict of their minor children is primary and not subsidiary and that responsibility shall cease when the persons can prove that they observe all the diligence of a good father of a family to prevent damage. However, Wendells mother testified that her husband owns a gun, which he kept in a safety deposit box inside a drawer in their bedroom. Each of the spouses had their own key. She likewise admitted that during the incident, the gun was no longer in the safety deposit box. Wendell could not have gotten hold of the gun unless the key was left negligently lying around and that he has free access of the mothers bag where the key was kept. The spouses failed to observe and exercise the required diligence of a good father to prevent such damage.

PEOPLE VS. TANEO FACTS: Potenciano Taneo and his wife lived in his parents house in Dolores, Ormoc. On January 16, 1932, a fiesta was being celebrated in the said barrio and guests were entertained in the house, among them were Fred Tanner and Luis Malinao. Early that afternoon, Taneo went to sleep and while sleeping, he suddenly got up, left the room bolo in hand and, upon meeting his wife who tried to stop him, wounded her in the abdomen. He also attacked Fred and Luis and tried to attack his father, after which, he wounded himself. Taneos wife, who was 7 months pregnant at that time, died five days later as a result of the wound. The trial court found Taneo guilty of parricide and was sentenced to reclusion perpetua. It appears from the evidence that the day before the commission of the crime, the defendant had a quarrel over a glass of tuba with Collantes and Abadilla, who invited him to come down and fight. When he was about to go down, he was stopped by his wife and his mother. On the day of the commission of the crime, it was noted that the defendant was sad and weak, had a severe stomachache thats why he went to bed in the early afternoon. The defendant stated that when he fell asleep, he dreamed that Collantes was trying to stab him with a bolo while Abadila held his feet. Thats why he got up and it seemed to him that his enemies were inviting him to come down; he armed himself with a bolo and left the room. At the door, he met his wife who seemed to say to him that she was wounded. Then, he fancied seeing his wife really wounded and in desperation wounded himself. As his enemies seemed to multiply around him, he attacked everybody that came his way. ISSUE: WON defendant acted while in a dream. HELD: Yes. The defendant acted while in a dream & his acts, therefore, werent voluntary in the sense of entailing criminal liability. Defendant not criminally liable for the offense. Orderd that he be confined in the government insane asylum. RATIO: The apparent lack of motive for committing a criminal act does not necessarily mean that there are none, but that simply we do not know them. Although an extreme moral perversion may lead a man to commit a crime without a real motive but just for the sake of committing it. In the case at hand, the court found not only lack of motives for the defendant to voluntarily commit the acts complained of (read: he loved his wife dearly, he tried to attack his father in whose house the lived and the guests whom he invited), but also motives for not committing the acts. Dr. Serafica, an expert witness in the case, stated that considering the circumstances of the case, the defendant acted while in a dream, under the influence of a hallucination and not in his right mind. The wifes wound may have been inflicted accidentally. The defendant did not dream that he was assaulting his wife, but that he was defending himself from his enemies.

PEOPLE vs. PACANA FACTS: Provincial secretary Pedro A. Pacana is being tried for falsification of public documents and for unlawfully taking P 25in purpose of permitting the district engineer to incur illegal expenses in the reconstruction of a provincial road and four other charges of the same nature. On June 18, 1923, an error of dates were seen in the minutes of the meeting by the provincial board with regard to a number of resolutions that were decided on the by board. Efforts to rectify these mistakes were done by the provincial board which effected another error. After which, the original copies of the resolutions (Exhibit C and D) disappeared probably by the hand of the defendant. It is alleged by the prosecution that the said documents were prepared by the provincial secretary with the connivance of the members of the provincial board for illegal purposes. The defense claims that it is merely a mistake and carelessness of the provincial secretary and the amount of work which caused his preoccupation that the error was committed, that there was no real intent to commit such a crime. ISSUE: WON a lack of criminal intent to falsify documents can acquit the defendant. HELD: YES. Evil intent must unite with an unlawful act for it to become a crime. RATIO: The court cannot find any source of intent on the side of the defendant; that all errors and alleged falsifications were all due to his carelessness, lack of experience, and lack of qualifications for the job. The accused does not stand to gain from any of these acts especially for a small amount of P 25 which he can easily earn from the same proceedings legally.