G.R. Nos. 111206-08 October 6, 1995
People of the Philippines vs. Claudio Teehankee, Jr.

FACTS

Accused-appellant Claudio Teehankee, Jr. was charged with Murder for the killing of Roland John Chapman and Frustrated Murder for the shooting of Jussi Olavi Leino and Maureen Hultman. After Hultman died during trial, the charge was amended to Murder. A petition for bail was filed concerning the murder charge for Chapman’s death. At the bail hearing, the prosecution sought to present survivor Jussi Leino to testify on all three incidents, arguing they constituted one continuing event. The defense initially objected, deeming testimony on the other charges irrelevant to the bail petition for Chapman’s murder. The parties eventually agreed to defer the bail hearing, proceed with arraignment, and thereafter conduct a joint trial on the merits and hearing on the petition for bail. Accused pleaded not guilty, and trial commenced without defense objection to the consolidated presentation of evidence.
The evidence established that in the early morning of July 13, 1991, Leino was walking Maureen Hultman home in Dasmariñas Village when accused, driving a Mitsubishi Lancer, stopped and confronted them. Accused demanded identification, took Leino’s wallet, and then shot Leino in the head. Roland Chapman, who was waiting in a nearby car, approached and was also shot by accused. Accused then shot Maureen Hultman in the head before fleeing. Chapman died instantly; Leino survived after medical treatment; Hultman later died from her wounds.

ISSUE

Whether the trial court committed reversible error in convicting the accused of the crimes charged.

RULING

The Supreme Court affirmed the convictions. The Court found the testimony of eyewitness Jussi Leino to be credible, consistent, and sufficient to establish accused’s guilt beyond reasonable doubt for the crimes of Murder and Frustrated Murder. The Court rejected the defense of alibi and denial, which could not prevail over Leino’s positive identification. The qualifying circumstances of treachery were correctly appreciated for the murders of Chapman and Hultman, as the attacks were sudden and unexpected, denying the victims any chance to defend themselves. For the shooting of Leino, the crime was properly classified as Frustrated Murder, as the gunshot wound to the head was fatal, and only timely medical intervention prevented death, constituting a stage where all acts of execution were performed. The Court also upheld the trial court’s procedure in conducting a joint hearing on the petition for bail and trial on the merits, as it was done with the agreement of the defense and did not prejudice the accused’s rights. The penalties and awards of damages were affirmed, with modifications to conform to prevailing jurisprudence.