Case Summary (G.R. No. 261972)
Applicable Law
The case is primarily governed by the Revised Penal Code of the Philippines, specifically Article 248, which criminalizes murder. Additionally, Republic Act No. 7610 is relevant due to the victim's status as a minor. The defense strategy invoked by the appellant is rooted in the principles of insanity as an exempting circumstance under the Revised Penal Code.
Summary of Events
On the date of the incident, the mother of the victim, EEE261972, was cooking while her children played nearby. A commotion ensued when another child, BBB261972, entered their home shouting that he had been hacked on the head. Shortly thereafter, Concepcion, brandishing a bolo, attacked EEE261972 while she attempted to protect BBB261972. Following the attack, the victim, AAA261972, and another sibling, CCC261972, were left unconscious and bloodied. Efforts to save them were made, but AAA261972 succumbed to injuries shortly after being transported to the hospital.
Evidence Presented
The prosecution's case included testimony from witnesses, including EEE261972 and Bebing Ilao, who recounted the horrifying events. Police Officer III Ferdinand Barcedo provided evidence of the immediate aftermath, including the arrest of Concepcion who attempted to flee, discarding the weapon in the process. The bolo, found to be stained with blood, was seized as evidence.
Defense Strategy
The defense for Concepcion posited that he was suffering from a mental illness defined as insanity. Dr. Lalyn Irene Marzan y Delos Reyes testified on behalf of Concepcion, asserting that he had a history of psychosis and was diagnosed with schizophrenia. However, her testimony revealed that Concepcion was considered competent to stand trial and was in a state of remission at the time of the incident.
Trial Court Decision
The RTC found Concepcion guilty beyond reasonable doubt of murder and imposed the penalty of reclusion perpetua. The court concluded that the evidence adequately established all elements of murder, particularly the qualifying circumstance of treachery due to the vulnerability of the minor victim.
Court of Appeals Decision
Upon appeal, the CA affirmed the RTC's decision but modified the damages, determining lesser civil indemnity while also ordering exemplary damages. The CA held that Concepcion failed to overcome the presumption of sanity and that evidence presented was sufficient to affirm guilt.
Key Legal Findings
The Supreme Court reiterated that the burden of proving insanity lies with the accused and must be substantiated by clear and convincing evidence. The court underscored that evidence must relate to the accused's me
...continue readingCase Syllabus (G.R. No. 261972)
Case Background
- This case arises from an appeal challenging the Decision of the Court of Appeals (CA) in CA-G.R. CR-HC No. 14486.
- The CA affirmed with modifications the Regional Trial Court (RTC) judgment in Criminal Case No. 17040, convicting Mark Angelo Concepcion y BacuAo (Concepcion) of murder related to Republic Act No. 7610.
Accusation and Proceedings
- Concepcion was charged with the murder of a one-year and seven-month-old minor, AAA261972, on October 15, 2015.
- The Information alleged that Concepcion, with intent to kill and with treachery, attacked the victim using a bladed weapon (bolo), inflicting fatal wounds.
Trial and Testimonies
- During the trial, the prosecution presented several witnesses:
- EEE261972, the victim's mother, testified about the attack on her family, including her fleeing children.
- Bebing Ilao, a neighbor, described her attempts to assist AAA261972 and CCC261972, who were found unconscious and bleeding.
- Police Officer III Ferdinand Barcedo provided details of his arrest of Concepcion, who was identified by the victim's mother as the attacker, and described the bolo as evidence.
Defense Strategy
- Concepcion entered a plea of "not guilty" and later invoked a defense of insanity.
- Dr. Lalyn Irene Marzan y Delos Reyes testified about Concepcion's mental health history, claiming he was diagnosed with psychos