Case Summary (G.R. No. 111206-08)
Bail Petition and Arraignment Strategy
- Bail set at ₱20,000 for each frustrated murder count; none for Chapman homicide.
- Defense objected to evidence on other counts during bail hearing.
- Parties agreed to combine trial on merits with bail petition after August 14, 1991 arraignment.
- Accused pleaded not guilty to all three charges.
Facts of the Shooting Incident
- After a party and visits to pubs, Leino drove Chapman and Hultman home in Dasmariñas Village past 3 a.m.
- On Mahogany Street corner, Teehankee’s Mitsubishi Lancer blocked them. He demanded IDs.
- He shot Chapman first in the chest, then, after ordering Leino and Hultman to sit defenseless on the sidewalk, shot Leino in the jaw and Hultman in the head.
- Teehankee fled in his silver-gray Lancer bearing plate PDW 566.
Eyewitness Accounts and Car Description
- Three subdivision security personnel—Domingo Florece, Vicente Mangubat, Agripino Cadenas—saw the shootings under Meralco streetlights.
- Florece noted “medyo puti” (somewhat white) Lancer, plate “566.”
- Mangubat and Cadenas gave plate PDW 566; described the car as silver-gray.
- All three witnessed Teehankee’s gunmanship and aided in transporting victims to Makati Medical Center.
Makati Police and NBI Investigation
- Makati Police Patrolman Baldado and SPO3 Fernandez began inquiry, traced plate to two Lancers: one sold by Montano, one registered to Teehankee.
- NBI Special Operations Group under Chief Salvador Ranin took over.
- On-the-spot interviews with Florece, Cadenas, Mangubat; neighborhood inquiry confirmed plate and location.
- Montano’s car exonerated; Teehankee’s car seized under search warrant; keys obtained from his mother.
Identification Procedures and Witness Cooperation
- Cadenas identified Teehankee from ten-photo array at NBI on July 16, 1991.
- Live line-ups conducted: at NBI office (Cadenas), at Makati Police Station (Mangubat), at Forbes Park under U.S. embassy protection (Leino).
- All three witnesses positively identified Teehankee as the gunman.
- Initial reluctance by Cadenas due to fear was assuaged by NBI protection assurances.
Medical Evidence on Victim Injuries
- Dr. Pedro Solis: Leino’s bullet wound fractured maxillary bone, lacerated tongue, caused brain contusions and hemorrhage; resulted in speech difficulty.
- Dr. Leovigildo Isabela: Hultman’s head wound caused brain tissue extrusion, multiple surgeries, eventual death on October 17, 1991.
Defense Evidence and Alibi Claim
- Teehankee testified he was in Pasig on July 13, 1991; maids would corroborate.
- Admitted car ownership but claimed it was non-running since February 1991 accident.
- Son testified he drove car in February 1991, then parked it in Makati.
- Paraffin test on Teehankee’s hands (July 17) was negative, performed over 72 hours post-incident.
- Raised theory implicating Anders Hultman, adoptive father of Maureen, based on overheard words “Daddy.”
Newspaper Accounts and Media-Based Defense
- Defense presented seven reporters and clippings from Manila Times, Inquirer, Malaya, People’s Journal, Manila Bulletin.
- Clippings suggested conflicting car color, other suspects, jealous-father theory, police disagreement.
- Counsel alleged witness torture at NBI and biased congressional pressure.
Trial Court Findings and Conviction
- RTC Branch 145 convicted Teehankee:
• Case No. 91-4605 (Chapman): Murder with treachery; Reclusion Perpetua; ₱50,000 indemnity; ₱500,000 damages.
• Case No. 91-4606 (Hultman): Murder with treachery; Reclusion Perpetua; ₱50,000 indemnity; ₱2,350,461.83 actual; ₱13,000,000 earning capacity; ₱1,000,000 moral/exemplary.
• Case No. 91-4607 (Leino): Frustrated murder with treachery; eight to ten years prision mayor; ₱30,000 indemnity; ₱118,369.84 actual; US$55,600 equivalent actual; US$40,000 loss earnings; ₱1,000,000 moral. - Attorney’s fees ₱3,000,000 total; costs taxed; bail denied.
Appellant’s Assignments of Error
- Alleged unreliable out-of-court identifications.
- Failure to prove guilt beyond reasonable doubt.
- Prejudicial media coverage deprived fair trial.
- Treachery not established.
- Excessive damages and loss of earning capacity awards.
- Excessive attorney’s fees award.
- Trial court erred by submitting merits and bail petition together, denying further defense evidence.
Supreme Court on Identification Reliability
- Applied 5-factor totality-of-circumstances test (viewing opportunity, attention, description accuracy, certainty, time lapse).
- Upheld identifications as fair, non-suggestive, necessary for witness safety.
- Rejected claims of photograph exposure, sketch suppression, insufficient viewing time.
- Noted paraffin test unreliability and possible hand-washing effects.
Treachery and Offense Reclassification
- Murder of Chapman lacked deliberate, r
Case Syllabus (G.R. No. 111206-08)
Procedural Posture
- Three Informations filed on July 13, 1991 in Makati RTC Branch 145 against Claudio Teehankee, Jr.:
• Murder of Roland John Chapman (Crim. Case No. 91-4605)
• Frustrated Murder of Jussi Olavi Leino (Crim. Case No. 91-4607)
• Frustrated Murder of Maureen Hultman, later amended to Murder upon her death (Crim. Case No. 91-4606) - Bail set at ₱20,000 each for frustrated murder counts; none for murder count
- Accused’s petition for bail heard August 9, 1991; arraignment August 14, 1991
- Prosecution presented evidence on all three cases simultaneously, defense raised no objection
- Trial court convicted on December 22, 1992; sentenced to:
• Reclusion perpetua for two murders
• Indeterminate prision mayor for frustrated murder
• Civil indemnities, moral/exemplary damages, attorney’s fees, costs - Motion for new trial denied; appeal filed raising seven assignments of error
Facts of the Case
- July 12–13, 1991: Leino, Chapman, Hultman at a party and pubs in Makati; thereafter Leino drove Hultman home in Dasmariñas Village
- At Mahogany & Caballero corner, a light-colored Mitsubishi Lancer (plate control “566”) blocked their path
- Driver (accused) demanded IDs, grabbed Leino’s wallet, shot Chapman when he intervened
- Ordered Leino to sit; chased and caught Hultman as she fled, forced both to sit side by side
- Accused then shot Leino in the head and Hultman in the forehead before fleeing in his Lancer
- Chapman died on the spot; Leino survived with severe craniofacial injuries; Hultman died October 17, 1991 after prolonged hospitalization
Prosecution Evidence
- Eyewitnesses at scene:
• Leino (surviving victim) – identified accused in multiple lineups and photo arrays
• Security guards Florece & Cadenas, and driver Mangubat – saw vehicle, gunman, plate “PDW 566” - NBI and Makati Police investigation:
• Traced Lancer with plate “PDW 566” to Teehankee residence; ruled out other “566” Lancer owners
• Obtained search warrant; seized accused’s silver-gray 1983 Lancer, plate PDW 566
• Multiple out-of-court identifications under NBI/SOG and Makati Police supervision - Medical testimony on injuries:
• Dr. Solis – Leino’s gunshot wound, bone fractures, contusions, speech difficulties
• Dr. Isabela – Hultman’s brain surgeries (three operations), fatal trajectory through vital brain areas
Identification and Eyewitness Testimony
- Photo lineup at NBI parking: Cadenas and Mangubat each selected accused’s photograph
- Seven-man physical lineup at NBI office and at Forbes Park: both Cadenas and Leino positively identified accused
- Leino’s hospital interview: despite trauma to tongue, wrote request to remove sunglasses, then identified accused
Defense Evidence and Alibi
- Accused denied presence at scene; claimed he was home in Pasig from 1 a.m. to 8–9 a.m.