G.R. No. 250895 - People vs. Lalap

On August 4, 1997, at around 10:00 p.m., in Barangay San Gabriel, Victoria, Oriental Mindoro, Mario Lalap (accused-appellant) was charged with the murder of Honorio Villanueva (victim).
The Information alleged that accused-appellant stabbed the unarmed victim from behind while the latter was having his meal at home. The stabbing caused mortal wounds which led to the victim’s death after ten days.
The crime was charged as Murder under Article 248 of the Revised Penal Code (RPC), with the qualifying circumstances of treachery and evident premeditation.

Testimonies of Joy Villanueva (victim’s daughter) established that accused-appellant entered their house via the kitchen door and stabbed her father first at the back and then at the belly as the victim attempted to resist.
The stabbing was accompanied by curses and insults directed at the victim. The attack lasted approximately nine minutes.
Honorio was taken to the hospital where he died ten days later from his injuries.

Accused-appellant testified that he was involved in a drinking session with the victim and others earlier that evening.
An altercation ensued because the victim allegedly gossiped about accused-appellant’s sister.
When accused-appellant passed by the victim’s house later, the victim called him, grabbed him by the collar, and accused-appellant stabbed the victim in anger as a result of losing control.
Accused-appellant claimed self-defense, asserting that the victim was the unlawful aggressor.
He learned later from his wife that the victim's condition worsened, eventually resulting in death.

The Regional Trial Court (RTC), Branch 40, City of Calapan, convicted accused-appellant of murder and sentenced him to reclusion perpetua, awarded damages to victim’s heirs, and rejected the plea of self-defense for lack of proof.
The Court of Appeals (CA), in CA-G.R. CR-HC No. 09221, affirmed the RTC decision but increased the amounts for moral and exemplary damages.
Accused-appellant appealed to the Supreme Court, maintaining the presence of self-defense, challenging the treachery qualification and causation of death.

Whether the CA erred in affirming the RTC’s conviction of accused-appellant for murder despite the asserted presence of all the elements of self-defense.
Whether the CA erred in affirming the RTC’s finding of murder qualified by treachery despite the alleged insufficiency of evidence.
Whether the CA erred in affirming the RTC’s conviction despite the alleged absence of evidence linking the injuries sustained by the victim as the proximate cause of death.