Passion and obfuscation
For passion or obfuscation as a mitigating circumstance to be considered, it must be shown that (1) an unlawful act sufficient to produce passion and obfuscation was committed by the intended victim; (2) that the crime was committed within a reasonable length of time from the commission of the unlawful act that produced the obfuscation in the accused’s mind; and that (3) the passion and obfuscation arose from lawful sentiments and not from a spirit of lawlessness or revenge. (Romera vs. People, G.R No. 151978, 14 July 2004, 434 SCRA 467)
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