US vs Dela Cruz
G.R. No. L-7094, March 29, 1912
Digest by : Mary Argentine Sophia C. Jamis-Lagsa
Topic : Immediate Vindication of a Grave Offense
Doctrine of the case :
In the case of United States v. De la Cruz, the defendant's conviction of
homicide in the Philippines is upheld, but the court considers the extenuating
circumstance of passion and obfuscation, reducing the sentence from fourteen
years to twelve years of reclusion temporal.
Facts of the case :
Conviction: Hilario De la Cruz was found guilty of homicide by the lower court.
De la Cruz killed his querida after catching her in flagrante delicto with a mutual
acquaintance in the Philippines.
The trial court sentenced him to fourteen years, eight months, and one day of
reclusion temporal.
The court did not consider any aggravating or extenuating circumstances in its
decision.
De la Cruz appealed, arguing that passion and obfuscation should be considered
as an extenuating circumstance under subsection 7 of article 9 of the Penal
Code.
Hilario De la Cruz was found guilty of homicide by the lower court.
Issue :
Whether or not De la Cruz’s act committed under the extenuating circumstance
described in subsection 7 of Article 9 of the Penal Code?
Should the penalty be adjusted to account for this mitigating circumstance?
Ruling :
The Supreme Court ruled that the extenuating circumstance of passion and
obfuscation should be considered.
The sentence was reduced from fourteen years, eight months, and one day of
reclusion temporal to twelve years and one day of reclusion temporal.
Ratio:
The decision was based on evidence that De la Cruz acted in the heat of passion
upon discovering his querida in flagrante delicto with another man.
Penal Code Reference: Subsection 7 of article 9 of the Penal Code states that
acting upon an impulse so powerful as to naturally produce passion and
obfuscation is an extenuating circumstance.
Case Distinction: The court distinguished this case from U.S. vs. Hicks, where
actions were premeditated and driven by vexation and anger.
Sudden Reaction: De la Cruz’s actions were a sudden reaction to his lover's
infidelity, naturally producing passion and obfuscation.
