**The United States vs. Hilario de la Cruz (22 Phil. 429)**
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### Facts:
Hilario de la Cruz was charged and convicted of homicide by a lower court in the Philippines. The conviction stemmed from an incident where De la Cruz, acting in the heat of passion, killed his lover (querida) after discovering her engaged in sexual relations with a mutual acquaintance. De la Cruz argued that he acted under an intense emotional impulse upon making this discovery.
The trial court did not consider any mitigating or aggravating circumstances and sentenced De la Cruz to 14 years, 8 months, and 1 day of **reclusion temporal** (medium degree of penalty as prescribed by the Penal Code).
De la Cruz appealed the decision, seeking to have the sentence reduced by acknowledging the extenuating circumstance of “having acted upon an impulse so powerful as naturally to have produced passion and obfuscation” as set forth in subsection 7 of Article 9 of the Penal Code.
After procedural review, the case reached the Philippine Supreme Court.
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### Issues:
1. **Was De la Cruz’s act committed under the extenuating circumstance described in subsection 7 of Article 9 of the Penal Code?**
2. **Should the penalty be adjusted to account for this mitigating circumstance?**
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### Court’s Decision:
**Issue 1:**
– **Court’s Analysis:** The Supreme Court reviewed the circumstances surrounding the crime and distinguished the passionate impulse that drove De la Cruz to act. Unlike previous cases such as **United States vs. Hicks**, where the emotion stemmed from deliberate intention and sustained anger, De la Cruz’s actions were driven by a sudden and powerful emotional disturbance.
– **Resolution:** The Supreme Court concluded that the intense emotional response triggered by witnessing his lover engaged in a sexual act with another person constituted “passion and obfuscation” as defined in subsection 7, Article 9 of the Penal Code.
**Issue 2:**
– **Court’s Analysis:** With the acknowledgment of the extenuating circumstance, the penalty prescribed must be adjusted to its minimum degree.
– **Resolution:** The Supreme Court modified the original penalty by reducing it from 14 years, 8 months, and 1 day of reclusion temporal to 12 years and 1 day of reclusion temporal.
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### Doctrine:
The case established that the killing done in the heat of passion, triggered by an unexpected and profoundly emotional discovery, may qualify as an extenuating circumstance under subsection 7 of Article 9 of the Penal Code. This precedent underscores that intense emotional reactions to unanticipated personal betrayals can temper criminal responsibility.
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### Class Notes:
– **Key Elements:**
– **Reclusion Temporal:** The medium penalty prescribed for homicide in RPC.
– **Extenuating Circumstances:** Factors that can reduce the criminal responsibility of the offender.
– **Legal Statutes/Provisions:**
– **Article 9, subsection 7 of the Penal Code:** “The following are extenuating circumstances: That of having acted upon an impulse so powerful as naturally to have produced passion and obfuscation.”
– **Case Reference:** United States vs. Hicks, 14 Phil. Rep., 217 (precedent regarding extenuating circumstances).
– **Application in Context:** In this case, De la Cruz’s crime was categorized under “passion and obfuscation,” contrasting it from premeditated actions or those driven by illegitimate reasons.
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### Historical Background
During the early 20th century, the Philippines was under American sovereignty, and its legal system was highly influenced by both Spanish and American laws. This case reflects the transition wherein the Philippine legal system grappled with the nuances of applying Spanish Penal Code provisions within a new colonial context. The case also underpins the Supreme Court’s role in interpreting what constituted “extenuating circumstances” based on evolving societal and judicial standards.
This decision helped bridge traditional legal norms concerning crimes of passion with contemporary judicial perspectives during the period, influencing subsequent rulings on similar cases involving intense emotional disturbances.
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