People vs Teehankee

(G.R. Nos. 111206-08, October 6, 1995)

After a night out Jussi Leino was accompanying Maureen Hultman her home, along the
corner of Caballero & Mahogany streets was approached by the accused Teehankee Jr. when
Roland Chapman saw that there was a commotion the latter approached the former. A series
of events ensued where the accused fired his gun killing Chapman and mortally wounding
Hultman and Leino, subsequently fleeing the crime scene. 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. A full blown investigation developed where the
three witnesses have given their separate out-of-court identification of the suspect and as well
as the positive identification by the lone surviving victim of the accused.
Three (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.