say, helicopter is behind the hill and waits until a fighter passes low over the hill, and after that the helicopter shoots into the tail of the fighter? well, i think no fighter would fare well :) On the other side :

"The official report details how the F15 was able to lock on to the helicopters around 64 km. However did not get visual ID till 6-9 km.(Beyond-visual range combat wasn't practiced at this typical exercise) "

But why would fighter fly low? It would just shoot a missile from 10km height - unreachable height for helicopter and for many anti-aircraft missiles.