G.R. No. 1541 : January 27, 1905
THE UNITED STATES, plaintiff-appellee, vs. VICENTE SANTILLAN, defendant-appellant.

FACTS:
Vicente Santillan was charged with and found guilty of the crime of homicide by the trial court. The complaint alleged the specific circumstance of premeditation. However, the trial court, in its judgment, found that neither premeditation nor any other aggravating circumstance was present in the commission of the crime. The prosecution agreed with this finding on appeal. The trial court considered the extenuating circumstance of obfuscación (obduracy or passion and obfuscation).

ISSUE:
Whether the trial court correctly applied the law in convicting the defendant of homicide and in considering the extenuating circumstance of obfuscation, thereby imposing the corresponding penalty.

RULING:
The Supreme Court affirmed the judgment of the trial court. The Court held that the trial court correctly found the defendant guilty of homicide and properly considered the extenuating circumstance of obfuscation. Citing a decision of the Supreme Court of Spain dated February 20, 1884, the Court ruled that resentment arising from rivalry in love relations is a powerful instigator of jealousy and is prone to produce anger and obfuscation, which qualifies as an extenuating circumstance. No error was found in the proceedings. The penalty imposed by the trial courttwelve years and one day of reclusión temporal, an indemnity of P1,000 to the family of the deceased, and payment of costswas declared to be in full conformity with the law and the Penal Code. The judgment was affirmed with costs against the appellant.