G.R. No. 261972 , August 23, 2023
People of the Philippines, Plaintiff-Appellee, vs. Mark Angelo Concepcion y Bacuño, Accused-Appellant.

FACTS

An Information charged Mark Angelo Concepcion with Murder, in relation to Republic Act No. 7610 , for hacking to death AAA261972, a one-year-and-seven-month-old minor, with a bolo on October 15, 2015. The prosecution evidence established that while the victim’s mother, EEE261972, was cooking, her children, including the victim, were playing nearby. BBB261972 (another child) ran inside shouting he was hacked. Concepcion arrived, pushed them inside, uttered “Ano, EEE261972!”, and hacked EEE261972 five times on the head as she protected BBB261972. Concepcion then went to his mother’s house next door. EEE261972 followed and found her other children, CCC261972 and the victim AAA261972, lying unconscious and covered in blood. They were brought to the hospital, where AAA261972 died. A neighbor, Bebing Ilao, assisted and testified the victim was still breathing when carried but died around 1:00 p.m. Police officers arrested Concepcion after a chase; he surrendered, and they recovered the blood-stained bolo. The defense presented Dr. Lalyn Irene Marzan to prove Concepcion’s medical history of psychosis related to methamphetamine use and a subsequent diagnosis of schizophrenia, invoking the exempting circumstance of insanity. The Regional Trial Court (RTC) found Concepcion guilty of Murder in relation to R.A. 7610, sentenced him to Reclusion Perpetua, and ordered him to pay civil indemnity and moral damages. The Court of Appeals (CA) affirmed the conviction but modified the awards of damages. Concepcion appealed, arguing the CA erred in not giving probative weight to his insanity defense and in finding him guilty based on circumstantial evidence.

ISSUE

1. Whether the CA erred in affirming the RTC for not giving probative weight to Mark Angelo Concepcion’s defense of insanity.
2. Whether the CA erred in affirming the RTC in finding Mark Angelo Concepcion guilty of the crime of murder in relation to Republic Act No. 7610 based on circumstantial evidence.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the CA Decision with modifications to the damages.
1. On the Insanity Defense: The Court ruled that Concepcion failed to prove the exempting circumstance of insanity with clear and convincing evidence. The defense of insanity is in the nature of confession and avoidance, admitting the act but claiming exemption. For insanity to prosper, it must be shown that the accused suffered a complete deprivation of intelligence, reason, or discernment at the time of or immediately preceding the crime. The Court found the testimony of Dr. Marzan insufficient as it pertained to Concepcion’s condition in 2013 and 2014, not at the time of the crime in October 2015. The medical certificate indicated he was “psychiatrically cleared” upon discharge in 2014. Furthermore, his behavior before, during, and after the incident—such as fleeing, discarding the weapon, and surrendering—demonstrated consciousness of his guilt and a degree of rationality, negating complete deprivation of intelligence. The defense thus failed to overcome the presumption of sanity.
2. On Circumstantial Evidence: The Court held that the conviction was based on sufficient circumstantial evidence, which constituted an unbroken chain leading to the fair and reasonable conclusion that Concepcion was the perpetrator. The evidence included: (a) EEE261972’s testimony that Concepcion hacked her and her children; (b) the discovery of the victim and CCC261972 unconscious and bloodied immediately after Concepcion went to the house next door; (c) the victim’s death from hack wounds; (d) Concepcion’s arrest while carrying a blood-stained bolo; and (e) his flight, which indicated guilt. These circumstances met the required elements for circumstantial evidence to sustain a conviction.
The Court modified the awarded damages. Accused-appellant is ORDERED to pay the heirs of AAA261972: (a) PHP 75,000.00 as civil indemnity; (b) PHP 75,000.00 as moral damages; (c) PHP 75,000.00 as exemplary damages; and (d) PHP 50,000.00 as temperate damages. All amounts shall earn interest at 6% per annum from the finality of the decision until fully paid.