Bantug, Marc Angelo V. II-BSLM CASE DIGEST People of the Philippines vs. Claudio Teehankee, Jr. FACTS OF THE CASE:
On July 10, 1991 Maureen Hultman, Jussi Leino and Roland Chapman while walking along the corner of Caballero & Mahogany streets, was approached by the accused Teehankee jr. And after a series of events, the accused fired his gun killing Chapman and mortally wounding Hultman and Leino, then left. Leino, though mortally wounded mustered all his strength and called for help and noticed at least 3 people looking on from outside their house namely Vicente Mangubat, Domingo Florece and Agripino Cadenas. Mangubat, after the gunman sped away, ran outside his house, helped the victims and reported the incident to the proper authorities. During their Investigation the NBI and the Makati police asked Jussi Leino twice regarding the person who shot them; The first instance was On July 15, 1991 while Leino was still in the hospital, he was shown (3) pictures of different men by the investigators. He identified Claudio Teehankee Jr. as the gunman from the pictures. In order to confirm the identification made by Leino and other witnesses Cadenas and Mangubat who also pointed the accused as the gunman thru a separate out –of court identification procedures. The Assistant director of NBI Epimaco Velasco, the Chief of NBI-Special operations group Salvador Ranin and 2 other agents brought the accused to Forbes park for further identification by the surviving victim, Jussi Leino. Leino has just been discharged from the hospital the day before. Since his parents were worried about his safety, they requested the NBI to conduct the investigation of the gunman in Forbes Park where the Leinos also live. The NBI agreed. So, the security agents from US embassy fetched Leino at his house and his father to a vacant house in Forbes Park. After a couple of minutes, Leino was brought out of the laws and placed in a car with slightly tinted windows. The car was parked about 5 meters away from the house. Inside the car with Leino was his Father, NBI-SOG chief Salvador Ranin and a driver. Leino was instructed to look at men who will be coming out of the house and identify the gunman from the line up. A group of five to six men (including the accused) then came out of the unoccupied house, into the street. From the group, Leino identified the accused as the gunman for the second time. 3 separate criminal cases were filed against accused Claudio Teehankee, Jr. Initially, he was charged with: MURDER for the killing of ROLAND CHAPMAN, and two (2) FRUSTRATED MURDER for the shooting and wounding of JUSSI LEINO and MAUREEN HULTMAN. When Hultman subsequently died after 97 days of confinement at the hospital and during the course of the trial, the Information for Frustrated Murder was amended to MURDER. The trial court convicted the accused Claudio Teehankee jr. because the strength of the testimonies of 3 eyewitnesses who positively identified him as the gunman. However, in his appeal, he vigorously assailed the validity of the out-of-court identification by these eyewitnesses especially the identification of Jussi Leino. ISSUE:
Whether or not the out-of-court identification in this case is a valid and licit way in the identification of the accused? HELD:
Out-of-court identification is conducted by the police in various ways. It is done thru show-ups where the suspect alone is brought face to face with the witness for identification. It is done thru mug shots where photographs are shown to the witness to identify the suspect. It is also done thru line-ups where a witness identifies the suspect from a group of persons lined up for the purpose. Since corruption of out-of-court identification contaminates the integrity of in-court identification during the trial of the case, courts have fashioned out rules to assure its fairness and its compliance with the requirements of constitutional due process. (People vs. Teehankee jr. 249 SCRA 54-125, pg 95). Based on this statement given by the high court regarding the issue, we can say that out-of the court identification of the accused is valid and licit when it is in line with the rules that the Supreme court have
fashioned. In the case given, the authorities did not violate anything stated in the latter, otherwise it is stated in the decision that they violated one. Wherefore, the out of court identification in this case is valid and licit. Which makes the contention of the accused regarding the validity of the identification, groundless.
