It was an evil and ferocious killing of an 10-month-old baby boy with no explanation.
Harley Hicks used a homemade baton made of copper wire wrapped in tape to bludgeon Zayden Veal-Whitting more than 30 times about the face and head during a burglary spree in Bendigo in June 2012.
Zayden's murder will haunt his mother, 24-year-old Casey Veal, forever.
"Zayden was my mini-me, full of my physical appearance. Just catching my own reflection can destroy my day in seconds if I'm not strong enough," Ms Veal said.
"Just the simplest moment can destroy my heart and mind."
Ms Veal found Zayden covered in blood in his cot.
"Some days I am scared to close my eyes to relive that experience again."
She says she is a shadow of her former self.
Zayden's older brother, five-year-old Xavier, has also been shattered.
"His grief has consumed my daily life," Ms Veal said in a victim impact statement.
"I constantly worry about his thoughts and sometimes what he has to express.
"For his age, he has lived through more than most adults - without a large voice and a large vocabulary."
Prosecutor Michelle Williams SC said no one would ever know what sparked the attack, but said perhaps baby Zayden stirred.
"We consider what he did was an extreme, extreme way to respond to any thought of self-preservation, to react in such a violent way," she said on Monday.
"It is an evil killing without any rational explanation."
Prosecutors want Hicks, 21, jailed for life but with a minimum term.
Ms Williams compared the case to other child killers like Robert Farquharson, who drowned his three boys in a car on Father's Day 2005.
Farquharson is serving a life term with a minimum non-parole period of 33 years.
"This is different, in some ways maybe worse, because this was a cold, calculated killing of a baby in a vacuum," she told the Victorian Supreme Court, sitting in Bendigo.
Defence barrister David Gallowes said Hicks used the drug ice before the murder.
"Perhaps it goes some way to explain the inexplicable," he said.
He urged the judge to consider other sentencing options, citing Hicks' troubled childhood, drug and alcohol use, attention deficit hyperactivity disorder, anti-social personality disorder and youth.
"There is some prospect of rehabilitation even if the prognosis is poor," Mr Gallowes said.
But Justice Stephen Kaye said he was concerned Hicks carried the baton intending to use it "if necessary".
"You couldn't argue the proposition that this case falls squarely into the most serious cases of murder," Justice Kaye said.
Ms Williams said Hicks had an extensive criminal record, with nine court appearances before his murder trial dating back to 2007 for crimes including wilful damage, thefts and burglaries, and had breached almost all orders made against him.
The last, a community corrections order for a 2011 armed robbery, was made two months before Zayden's murder.
Hicks, of North Bendigo, will be sentenced on a date to be fixed.
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