G.R. No. 229829 January 22, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. ARNEL KALIPAYAN y ANIANO, Accused-Appellant

FACTS

Accused-appellant Arnel Kalipayan was charged with the murder of his former live-in partner, Glaiza Molina, inside her house on June 25, 2008. The prosecution presented eyewitnesses, including the victim’s mother and grandmother, who testified that Kalipayan entered the house without permission and suddenly and repeatedly stabbed Glaiza while she was cooking in the kitchen. The attack was so sudden that the victim, who was unarmed, could not defend herself. The police later arrested Kalipayan and recovered the knife. The medico-legal report detailed multiple stab wounds.
The defense presented a different version, claiming Kalipayan went to the house to confront Glaiza about a suspected affair. He alleged an argument ensued, Glaiza slapped him, and he then grabbed a knife from the sink and stabbed her in a fit of rage, claiming he lost control and had no intent to kill.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of the accused-appellant for the crime of Murder, qualified by treachery.

RULING

The Supreme Court affirmed the conviction for Murder. The Court upheld the presence of treachery (alevosia) as a qualifying circumstance. The legal logic requires that the means of execution be deliberately adopted by the offender to ensure the commission of the crime without risk to himself from any defense the victim might make. The prosecution evidence clearly established that the attack was sudden and unexpected. The victim was stabbed from behind while cooking, rendering her utterly unable to defend herself or repel the assault. This manner of attack directly and specifically ensured the execution of the crime without any risk to the accused-appellant.
The Court rejected the defense of passion and obfuscation. For this mitigating circumstance to apply, it must arise from lawful sentiments, not from jealousy or a lover’s quarrel. The Court found that the facts did not constitute the “immediate vindication of a grave offense” required by law. Furthermore, the number, location, and severity of the wounds belied any claim of lack of intent to kill and instead indicated a determined assault. The aggravating circumstance of dwelling was not appreciated, as the prosecution failed to prove the accused purposely sought the house’s seclusion to commit the crime. The penalty of reclusion perpetua without eligibility for parole was affirmed, and damages were awarded to the victim’s heirs.