PEOPLE VS. CLAUDIO TEEHANKEE, JR.

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

DOCTRINE:
While eyewitness identification is significant, it is not as accurate and authoritative as the
scientific forms of identification evidence such as the fingerprint or DNA testing.

FACTS:
On July 10, 199, Maureen Hultman and Jussi Leino were walking, while Roland Chapman
remained in the car, when they were stopped by the accused Teehankee jr. Accused
alighted from his car, approached them. Chapman stepped down on the sidewalk and
asked accused: Why are you bothering us? Accused pushed Chapman, dug into his
shirt, pulled out a gun and fired at him. After series of events, the accused mortally
wounded Hultman and Leino, then left. Leino called for help and noticed at least three
people looking on from outside their houses namely Vicente Mangubat, Domingo Florece
and Agripino Cadenas. Mangubat ran outside his house and helped the victims and
reported the incident to the proper authorities. During the investigation, Leino and the three
witnesses identified Teehankee as the accused. Leino first identified the accused while he
was still in the hospital. For security reasons, the NBI conducted the second identification
in Forbes Park and while Leino was inside the slightly tinted car. The trial court convicted
the accused Claudio Teehankee jr. because of the strength of the testimonies of three
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 is valid?

RULING:
The Court ruled that it is understandable for the accused to assail his out-of-court
identification by the prosecution witnesses in his first assignment of error. Eyewitness
identification constitutes vital evidence and, in most cases, decisive of the success or
failure of the prosecution. Yet, while eyewitness identification is significant, it is not as
accurate and authoritative as the scientific forms of identification evidence such as the
fingerprint or DNA testing.

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.

There is nothing wrong in Leinos identification of the accused in an unoccupied house in

Forbes Park. The records reveal that this mode was resorted to by the authorities for
security reasons. There is no reason to doubt the correctness of the accused s
identification by Leino. The scene of the crime was well-lighted by a lamp post. The
accused was merely 2-3 meters away when he shot Leino. Leino had no ill-motive to
falsely testify against the accused. The Court also gave credence to the testimony of the
other two witnesses.

Therefore, using the totality of circumstances test, the alleged irregularities cited by the
accused did not result in his misidentification nor was he denied due process.