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People vs. De Los SantosMarch 31, 1950
Facts: Juan Delos Santos was charged and convicted of parricide for killing wife Mercedes.
One evening, Juan caught another man, their neighbor Asuerto, lying on top of his wife. Juan raised his bolo to slash the man but the bolo landed on Mercedes.
Held: Court denied his claim of 2 mitigating circumstance, 1) provocation, 2) passion and obfuscation. There was only one mitigating circumstance, passion and obfuscation because it arose from one and the same cause, should be treated as only one.
Sentenced to reclusion perpetua.