• This case involves Leopoldo Singcol, who was convicted for killing his father, Andres (parricide), and his sister-in-law, Egmedia (murder). After being a fugitive for many years, he was arrested and faced trial. The Supreme Court reviews his claims of self-defense and passional obfuscation (a state of emotional distress), ultimately affirming his convictions but modifying the reasoning for the parricide conviction.

• The Incident (February 4, 1986): Leopoldo argued with his father, Andres, and stabbed him to death with a knife. Shortly after, he attacked his sister-in-law, Egmedia, who was carrying her two-year-old son, Jonathan. He stabbed Egmedia, killing her, and also severely injured Jonathan, who survived.
• Fugitive and Arrest: Leopoldo went into hiding immediately after the crimes. He was arrested in 2022, almost 36 years later, after his grandchild posted a video of his birthday party on Facebook.
• Defense's Version: Leopoldo claimed a history of abuse by his father. He argued he acted in self-defense against Andres, who attacked him first. He claimed he was "out of his senses" when he attacked Egmedia and Jonathan.

• Trial Court (RTC) Ruling: The RTC convicted Leopoldo of parricide and homicide. It found his self-defense against his father was "incomplete" (mitigating his sentence) and that the killing of Egmedia was homicide, not murder. The charge related to injuring Jonathan was dismissed due to prescription (the time limit for prosecution had passed).
• Court of Appeals (CA) Ruling: The CA affirmed the parricide conviction but rejected the incomplete self-defense claim. It upgraded the homicide conviction to murder, finding that treachery was present in the attack on Egmedia.
• Appeal to the Supreme Court: Leopoldo appealed to the Supreme Court, seeking to overturn his convictions.

• Was Leopoldo's claim of self-defense in killing his father valid?
• Did the mitigating circumstance of passion and obfuscation apply to the killing of his father?
• Was the killing of his sister-in-law correctly qualified as murder due to treachery?

The Supreme Court dismissed the appeal and affirmed the convictions with modification.

• On Parricide (Killing of Andres): The Court rejected the self-defense claim because the aggression from his father had stopped when Leopoldo delivered the fatal blow. However, the Court recognized the mitigating circumstance of "passion and obfuscation," finding that Leopoldo acted from a burst of uncontrollable emotion stemming from a lifetime of abuse by his father. His immediate acts of remorse and self-harm supported this conclusion.
• On Murder (Killing of Egmedia): The Court affirmed the murder conviction, agreeing with the CA that treachery was present. Egmedia was attacked suddenly while in a vulnerable position (carrying her child on a slope), leaving her no opportunity to defend herself.

• Self-Defense: Requires unlawful aggression from the victim. If the aggression ceases, the right to self-defense also ceases. The person claiming it must prove all its elements.
• Passion and Obfuscation: A mitigating circumstance where a person commits a crime due to an uncontrollable burst of passion caused by a prior unlawful act. It requires that the emotion comes from legitimate feelings, not from a spirit of revenge.
• Treachery (Alevosia): Qualifies a killing to murder. It involves an attack that is sudden and deliberate, giving the victim no chance to defend themselves. Even a frontal attack can be treacherous if it is unexpected and the victim is defenseless.