G.R. No. 188331 ; June 16, 2010
People of the Philippines, Appellee, vs. Ryan Lalongisip y delos Angeles, Appellant.

FACTS

The appellant, Ryan Lalongisip, was charged with Murder for the killing of Romeo Copo. The prosecution’s version established that on March 8, 2006, during a drinking session at a house in Calabanga, Camarines Sur, the appellant suddenly stood up and stabbed the victim at the back as the latter was turning away to go to the kitchen. The attack was unprovoked, and the victim died from the single stab wound that penetrated his heart. The weapon, a kitchen knife, was recovered. The appellant surrendered to barangay officials afterward.
The defense presented a contrary account, claiming the incident was an accident. The appellant testified that he and the victim grappled for possession of a knife after the victim picked it up. He alleged that when he finally wrested control of the knife, he was in front of the victim, and he accidentally hit the victim’s back when the victim turned around. He cited a prior family feud as motive for the prosecution witnesses’ alleged biased testimony.

ISSUE

Whether the Court of Appeals correctly affirmed the appellant’s conviction for Murder, qualified by treachery.

RULING

The Supreme Court affirmed the conviction. The Court found the prosecution’s evidence, particularly the credible and consistent testimonies of eyewitnesses, sufficient to prove the appellant’s guilt beyond reasonable doubt. These witnesses clearly recounted how the appellant, without any provocation, stabbed the unsuspecting victim from behind while the victim was moving away. This manner of attack ensured the victim had no opportunity to defend himself, satisfying the element of treachery (alevosia) which qualified the killing as Murder.
The Court rejected the defense of accident. The appellant’s claim of a struggle was inconsistent with the physical evidence—a single, fatal stab wound located at the victim’s back. His act of immediately surrendering did not negate criminal liability but was more indicative of guilt. The established facts demonstrated a deliberate assault on a defenseless victim, not a regrettable accident. The penalty of reclusion perpetua was upheld. The Court modified the awarded damages, increasing civil indemnity and moral damages to ₱75,000.00 each and adding ₱30,000.00 as exemplary damages, all with legal interest.