G.R. No. 261972 - People vs. Mark Angelo Concepcion y Bacuao

On or about October 15, 2015, at approximately 11:00 a.m., the accused, Mark Angelo Concepcion y Bacuao, allegedly attacked a minor (identified as AAA261972, one year and seven months old) with a bladed weapon (bolo) within the jurisdiction of the court.
The Information charged Concepcion with murder in relation to Republic Act No. 7610, emphasizing the heinous nature of the crime given the victim’s tender age and inherent defenselessness.

During the incident, as testified by the prosecution, the victim’s mother (EEE261972) was cooking while her children played nearby. A commotion ensued when another child (BBB261972) rushed into the house, exclaiming that he was hacked on the head.
Concepcion arrived abruptly; he is reported to have pushed the occupants inside the house while exclaiming “Ano, EEE261972, Ano, EEE261972!” and subsequently hacked the victim’s head five times as the victim’s mother tried to protect her children.
After the attack, Concepcion fled to a neighboring house. The victim’s mother, along with a neighbor (Bebing Ilao), rescued the injured children and rushed them to the hospital. Bebing’s testimony also detailed her attempts to attend to the victim’s wounds and her observation of blood and white fluid from the injury.
Additional evidence came from Police Officer III Ferdinand Barcedo and his companions, who witnessed a gathering crowd, a distressed woman identifying Concepcion as the attacker, and observed Concepcion discarding the bloody bolo before fleeing. They eventually apprehended him after persuading him to surrender.

The prosecution presented physical evidence, including the bolo stained with blood and hair, marked and secured by law enforcement, reinforcing the chain of evidence linking Concepcion to the crime.
The circumstantial evidence was deemed sufficient, with details such as Concepcion’s actions during the incident (shouting, fleeing, discarding the weapon, and later surrendering) used to illustrate his awareness and deliberate conduct before, during, and after the offense.

Concepcion pleaded “not guilty,” invoking the defense of insanity. His defense rested primarily on the testimony of his sole defense witness, Dr. Lalyn Irene Marzan y Delos Reyes, who had previously diagnosed him with psychosis attributed to methamphetamine use and schizophrenia.
Dr. Marzan testified that while Concepcion had suffered from a mental illness since May 2013 and was under treatment, he was in a period of remission and declared competent to stand trial at the time of earlier evaluations.
However, during cross-examination, it was revealed that the relevant examinations covered periods significantly apart from the time of the offense, thus raising doubts as to whether Concepcion’s mental state at the time of the crime was accurately captured by his defense’s testimony.

The Regional Trial Court (RTC) found Concepcion guilty beyond reasonable doubt of murder under Republic Act No. 7610 and sentenced him to reclusion perpetua, along with ordering the payment of civil indemnity, moral, and exemplary damages to the heirs of the victim.
The Court of Appeals (CA) affirmed, with modifications, the RTC’s judgment—modifying the award of damages to specified amounts—while also upholding the conviction based on the circumstantial evidence and the insufficiency of the insanity defense.
Concepcion elevated the case to the Supreme Court on appeal, challenging the weight given to his insanity defense and the reliance on circumstantial evidence for his conviction.

Whether the Court of Appeals erred in not giving sufficient probative weight to Concepcion’s defense of insanity.
Whether the evidence presented, particularly the testimony of Dr. Marzan, meets the high standard of "clear and convincing evidence" required to establish a complete deprivation of intelligence at the time of the crime.

Whether the circumstantial evidence, including witness testimonies and physical evidence (such as the blood-stained bolo), sufficiently proves beyond reasonable doubt that Concepcion committed the crime.
Whether the actions observed before, during, and after the incident negate the possibility of a complete absence of intelligence typically necessary to support an insanity plea.

Whether the designation of treachery, by virtue of the victim’s youth and inherent vulnerability, is proper and legally sustainable.
Whether the presence of treachery in the commission of the crime obviates the need to designate the offense additionally as related to Republic Act No. 7610.