The Supreme Court (SC) recognized that a sudden outburst of uncontrolled emotions, triggered by years of abuse from the accused’s father, qualifies as passion or obfuscation – a mitigating circumstance that can reduce the penalty for parricide.
In a decision written by Associate Justice Ramon Paul Hernando and made public July 7, the SC’s First Division upheld Leopoldo Singcol’s conviction for killing his father but lowered the penalty due to the presence of this mitigating factor.
Singcol was having breakfast when his father arrived, carrying a bolo. An argument broke out, and his father attempted to attack him but stumbled and fell. Singcol grabbed the bolo and stabbed his father in the chest, killing him.
Singcol later encountered his sister-in-law and her two-year-old son. He attempted to stab her but injured the child instead. The mother then lost her grip on the boy, and Singcol fatally stabbed her. The child survived.
During trial, Singcol admitted to stabbing his father, his sister-in-law, and the child. He said he had suffered abuse from his father since childhood and was not thinking clearly when he attacked the others.
Both the Regional Trial Court and the Court of Appeals convicted Singcol of parricide for killing his father.
But while the SC agreed with their rulings that self-defense was not applicable in this case, it ruled that passion, or obfuscation, should be considered a mitigating factor or circumstance that lessens the penalty.
Under the Revised Penal Code, parricide is committed when the accused kills their parents or child, whether legitimate or illegitimate, or any of their ascendants or descendants, or legal spouse, the SC Office of the Spokesperson said.
Passion or obfuscation, on the other hand, is a state of mind present when a crime is committed due to an uncontrollable burst of emotions triggered by previous unjust or improper acts.
The SC considered the parricide a result of “a sudden surge of the accused’s bottled-up feelings caused by paternal neglect since childhood”, as shown by Singcol’s narration and his extreme, irrational acts of self-harm immediately after the killing.
Singcol was sentenced to reclusion perpetua, or a maximum of 40 years in prison, for the parricide and the murder of his sister-in-law, and ordered to pay the heirs of each victim P275,000 in damages.
The RTC dismissed the charge against Singcol for injuring his sister-in-law’s son due to prescription, as over 15 years had passed since the crime. ||
