People v. Santillan
REITERATIONFacts
The Antecedents: The defendant, Vicente Santillan, was accused and found guilty of homicide. Procedural History: The court below rendered a judgment finding the defendant guilty of homicide. The court below stated that neither the specific circumstance of premeditation, as alleged in the complaint, nor any other aggravating circumstance was present. The extenuating circumstance of obduracy was taken into consideration. The Petition: The defendant appealed the judgment of the court below.
Issue(s)
Whether the judgment of the court below, sentencing Vicente Santillan to twelve years and one day of reclusion temporal, to pay P1,000, Philippine currency, to the family of the deceased, and the costs, is in conformity with the law and the provisions of the Penal Code.
Ruling
The judgment of the court below is affirmed. Vicente Santillan is sentenced to twelve years and one day of reclusion temporal, to pay P1,000, Philippine currency, to the family of the deceased, and the costs.
Ratio Decidendi
On the sole issue of the conformity of the judgment with law: The Supreme Court affirmed the judgment of the court below. The Court noted that the court below had correctly found that neither the specific circumstance of premeditation, as alleged in the complaint, nor any other aggravating circumstance was present in the commission of the crime. The prosecution agreed with this finding. Furthermore, the extenuating circumstance of obduracy was well taken into consideration by the trial court. The Supreme Court cited a decision of the Supreme Court of Spain rendered on February 20, 1884, which stated that resentment for rivalry in love relations with a woman is a powerful instigator of jealousy and prone to produce anger and obduracy. The appellate court found no error in the trial below, nor was any alleged by the defense. Therefore, the judgment sentencing Vicente Santillan to twelve years and one day of reclusion temporal, to pay P1,000, Philippine currency, to the family of the deceased, and the costs, was deemed wholly in conformity with the law and the provisions of the Penal Code.
Main Doctrine
The judgment of the court below, sentencing the defendant to twelve years and one day of reclusion temporal for homicide, with indemnity and costs, is affirmed, considering the extenuating circumstance of obduracy arising from jealousy due to rivalry in love.