MANILA, Philippines—The Supreme Court has ruled that a sudden outburst of emotions caused by years of abuse may be considered a mitigating circumstance in a parricide case, reducing the penalty imposed on the accused.

In a decision penned by Associate Justice Ramon Paul L. Hernando, the SC’s First Division upheld the conviction of Leopoldo Singcol for killing his father but lowered the penalty, recognizing “passion or obfuscation” as a mitigating factor.

Singcol had been eating breakfast when his father arrived carrying a bolo. An argument ensued, during which his father tried to attack him but stumbled and fell. Singcol then seized the bolo and stabbed his father in the chest. Overcome by shock, Singcol embraced his father, asked for forgiveness, and attempted suicide by slashing his own throat and abdomen.

Following the incident, Singcol encountered his sister-in-law and her two-year-old son on the way to a spring. He tried to stab her but injured the child instead. As she lost her grip on the boy, Singcol fatally stabbed her. The child survived.

Singcol later admitted in court that he had stabbed his father, sister-in-law, and her son. He claimed that years of abuse at the hands of his father had clouded his judgment.

Both the Regional Trial Court and the Court of Appeals convicted Singcol of parricide. While the Supreme Court affirmed that self-defense was not applicable in the killing of his father, it held that the mitigating circumstance of passion or obfuscation applied due to the emotional toll of past abuse.

Under the Revised Penal Code, passion or obfuscation refers to a mental state in which a person commits a crime during a moment of intense emotional disturbance triggered by unjust or improper acts.

The SC noted that the parricide stemmed from “a sudden surge of the accused’s bottled-up feelings caused by paternal neglect since childhood,” as evidenced by Singcol’s narration and his subsequent self-harming behavior.

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

Meanwhile, the Regional Trial Court dismissed the charge for injuring the child, citing prescription of the offense, as more than 15 years had passed since the incident.