A sudden outburst of uncontrolled emotions, triggered by years of abuse by the accused’s father, qualifies as passion or obfuscation — a mitigating circumstance that can reduce the penalty for parricide, the Supreme Court ruled in a recent decision.

In a decision written by Associate Justice Ramon Paul L. Hernando dated 7 May 2025, 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.

The records showed 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.

The accused then grabbed the bolo and stabbed his father in the chest, killing him. Shocked at what he had done, he held his father, asking for forgiveness, and then he cut his own throat and abdomen.

On his way to a nearby spring afterward, Singcol encountered his sister-in-law and her two-year-old son. He attempted to stab her but injured the child instead.

The mother lost her grip on the boy and Singcol fatally stabbed her. The child survived. During the trial, Singcol admitted to stabbing his father, his sister-in-law, and the child.

He claimed he suffered abuse by his father since childhood and was not thinking clearly when he attacked the others.

The Regional Trial Court and the Court of Appeals convicted Singcol of parricide for killing his father.

While the Supreme Court agreed with them that self-defense was not applicable in this case, it ruled that passion or obfuscation should be considered as a mitigating factor or circumstance that lessens the penalty.

The Revised Penal Code says 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.

On the other hand, passion or obfuscation 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 High Court 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.

Reclusion perpetua, or a maximum of 40 years in prison, was meted out by the court on Singcol for the parricide and the murder of his sister-in-law and he was 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.