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, the Supreme Court ruled in a recent decision.

In a decision penned by Associate Justice Ramon Paul L. Hernando dated 7 May 2025, the SC First Division upheld the conviction of Leopoldo Singcol for killing his father but lowered the penalty due to this mitigating factor.

Records showed that 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 then grabbed the bolo and stabbed his father in the chest, killing him. Shocked by what he had done, he held his father, asked for forgiveness, and then attempted to take his own life by slashing his throat and abdomen.

On his way to a nearby spring, Singcol encountered his sister-in-law and her two-year-old son. He attempted to stab the woman but injured the child instead. When she lost her grip on the boy, Singcol fatally stabbed her. The child survived. During trial, Singcol admitted to stabbing his father, his sister-in-law, and the child.

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

Both the Regional Trial Court (RTC) and the Court of Appeals convicted Singcol of parricide for the death of his father. While the Supreme Court agreed that self-defense did not apply, it ruled that passion or obfuscation should be appreciated as a mitigating circumstance that reduced the degree of punishment.

Under the Revised Penal Code, parricide is committed when the accused kills a parent, child, ascendant, descendant, or spouse, whether legitimate or illegitimate. Passion or obfuscation refers to a state of mind in which a person commits a crime as a result of intense emotional disturbance caused by prior unjust acts.

The Court found that the killing was the result of “a sudden surge of the accused’s bottled-up feelings caused by paternal neglect since childhood,” supported by Singcol’s own account and his irrational self-harm immediately after the act.

Singcol was sentenced to reclusion perpetua, or a maximum of 40 years in prison, for the parricide and for the murder of his sister-in-law. He was also ordered to pay PHP 275,000 in damages to the heirs of each victim.

The RTC dismissed the charge for injuring the two-year-old child due to prescription, as more than 15 years had passed since the incident.