Title
People vs. Teehankee, Jr.
Case
G.R. No. 111206-08
Decision Date
Oct 6, 1995
Claudio Teehankee, Jr. convicted for 1991 Dasmarinas Village shooting, killing two and wounding one; eyewitnesses and forensic evidence proved guilt beyond reasonable doubt.

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

  1. Alleged unreliable out-of-court identifications.
  2. Failure to prove guilt beyond reasonable doubt.
  3. Prejudicial media coverage deprived fair trial.
  4. Treachery not established.
  5. Excessive damages and loss of earning capacity awards.
  6. Excessive attorney’s fees award.
  7. 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
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