G.R. No. L-33697 April 2, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CONSTANCIO L. CAUYAN, defendant-appellant.

FACTS

Constancio L. Cauyan was convicted by the Court of First Instance of Quezon for the murder of Claudia Amat and the frustrated murder of Andres Patron. The trial court sentenced him to twenty years of reclusion temporal for murder, considering the mitigating circumstance of passion and obfuscation, and an indeterminate penalty for frustrated murder. The prosecution evidence established that on the evening of April 7, 1961, appellant stabbed Claudia Amat multiple times at the foot of the stairs of her house. Upon seeing her son Andres rush to her aid, appellant also stabbed Andres, who survived after medical treatment. Witnesses testified that appellant had sharpened his knife earlier, stating he had many enemies, and was heard shouting threats at the Patron family after the attack.
Appellant claimed self-defense regarding Andres, alleging Andres first struck him. He contended the fatal wounds to Claudia were accidental, occurring as she held Andres during their struggle. The Court of Appeals, upon certification due to the penalty involved, reviewed the case and affirmed appellant’s guilt but rejected the trial court’s finding of the mitigating circumstance of passion and obfuscation.

ISSUE

Whether the mitigating circumstance of passion and obfuscation is correctly applicable to reduce appellant’s penalty for the crime of murder.

RULING

The Supreme Court affirmed the appellate court’s ruling and rejected the existence of passion and obfuscation as a mitigating circumstance. The legal logic requires that for this circumstance to be considered, two elements must concur: first, the act producing the emotional disturbance must be unlawful; second, it must not be far removed in time from the crime, allowing the perpetrator to recover normal equanimity. The Court found both elements absent.
The alleged cause of appellant’s passion was the act of Maximo Patron, the victim’s husband, in bailing out a priest whom appellant had criminally charged. The Court ruled this act of posting bail was not unlawful; it was a legitimate legal procedure. Furthermore, the act was not shown to be so proximate to the stabbing as to preclude a return to sober reflection. The Court deemed the reaction—directing vengeance against the bondsman’s wife—as not the natural and immediate impulse contemplated by law but indicative of pre-existing sinister motives. Consequently, with treachery qualifying the killing as murder and no mitigating circumstance present, the proper penalty is reclusion perpetua. The Court modified the trial court’s decision, imposing reclusion perpetua and increasing the civil indemnity.