| Decided 6 October 1995 | |
|---|---|
| Ponente Reynato Puno | |
| G.R. Nos. 111206-08 | |
| Unanimous Regalado, Mendoza and Francisco, JJ., concur; Narvasa, C.J., was on leave.[1] |
|
The Hultman-Chapman murder case (formally People of the Philippines vs. Claudio Teehankee, Jr.) was a murder case that gained wide publicity in the Philippines during the early 1990s because Claudio Teehankee, Jr., the perpetrator of the crime, was the son of the late former Chief Justice Claudio Teehankee and the brother of former Justice Undersecretary Manuel Teehankee. The case helped sway the public view and lawmakers on crime and restore the death penalty in the Philippines.[1]
Court records show that Roland John Chapman, Maureen Hultman, and another friend, Jussi Leino, were coming home from a party at around three o'clock in the morning of July 13, 1991. Leino was walking Hultman home along Mahogany street in Dasmariñas Village, Makati City when Teehankee came up behind them in his car. He stopped the two and demanded that they show some identification. Leino took out his wallet and showed Teehankee his Asian Development Bank ID. Teehankee grabbed the wallet. Chapman, who was waiting in a car for Leino, stepped in and asked Teehankee: “Why are you bothering us?” Teehankee drew out his gun and shot Chapman in the chest, killing him instantly. After a few minutes, Teehankee shot Leino, hitting him in the jaw. Then he shot Hultman on the temple before driving away. Leino survived and Hultman died two months later in hospital due to brain hemorrhages caused by the bullet fragments. Teehankee was arrested several days later on the testimony of several witnesses. The witnesses were Domingo Florence and Agripino Cadenas, private security guards, and Vincent Mangubat, a driver, all three being employs of residents of the village.
The Supreme Court of the Philippines, on March 6, 1992, dismissed Teehankee, Jr.'s certiorari petition to annul the trial court's admission of the amended information, the arraignment and appointment of PAO lawyer as counsel de oficio of Teehankee, Jr., inter alia.[2] On December 22, 1992, Judge Job B. Madayag, Makati City Regional Trial Court, Branch 145, convicted Teehankee, Jr.[3] The Supreme Court of the Philippines on October 6, 1995, modified the trial court's decision and found Teehankee, Jr. guilty of the crimes of murder, homicide and attempted murder, for which, he was meted out 3 sentences, respectively, reclusión perpetua (defined effectively as 30 years by the Revised Penal Code) and 2 indeterminate sentences of reclusion temporal, each for 8 years and 1 day to 14 years (now, as finally amended by the Supreme Court in 1995). Under Article 70 of the Revised Penal Code, the maximum combined sentences cannot exceed 40 years.[4] Teehankee, Jr. was ordered to pay civil indemnity: in Criminal Case No. 91-4605, 50,000.00 Philippine Pesos as indemnity for the Chapman's death; 1,000,000.00 Pesos as moral damages; in Criminal Case No. 91-4606, 50,000.00 Pesos as indemnity for Maureen Navarro Hultman's death; 2,350,461.83 Pesos as actual damages; 564,042.57 Pesos for loss of earning capacity; 1,000,000.00 Pesos as moral damages; and 2,000,000.00 Pesos as exemplary damages; in Criminal Case No. 91-4807, 30,000.00 Pesos as indemnity for Jussi Olavi Leino's injuries; 118,369.84 Pesos and equivalent in Philippine Pesos of U.S.$55,600.00, both as actual damages; 1,000,000.00 Pesos as moral damages; and 2,000,000.00 Pesos as exemplary damages; In all 3 cases, to pay each of 3 offended parties the sum of 1,000,000.00 Pesos for attorney's fees and expenses of litigation.[5]
The killings of Chapman and Hultman, together with other notable heinous crimes such as the murder of Eldon Maguan and the Vizconde massacre caused the Philippine Congress to restore the death penalty in the Philippines in 1993. The imposition of the death penalty had been suspended with the enactment of the 1987 Philippine Constitution.[6] The death penalty would again be barred in the Philippines after legislation to that effect was passed in 2006.
"Bobbins" or Claudio, Jr. started serving the sentence on June 24, 1991, by virtue of his preventive detention at the Makati City jail, and then, at New Bilibid Prison in Muntinlupa since January 16, 1993. On the civil aspect, the trial Court approved the November 19, 1999 settlement signed by the Hultman family and the Teehankees, on January 10, 2000. The lower court issued entry of judgment on February 17, 2000, and on January 13, 2003, the Hultmans filed the Notice of Satisfaction of Judgment. Accordingly, Bobbins filed the petition for executive clemency on December 22, 2003, since he already served a total of 13 years and 5 months of actual time, equivalent to 15 years under the Good Conduct Credits rules and guidelines. Formal notices of the application were published in the newspapers, inter alia, to all parties concerned, on January 28 and February 6, 2004 with no oppositions filed. By virtue of the Presidential Order of Commutation dated September 30, 2008, Bobbins is just one of 1,430 released who were similarly situated. Thus, on October 3, 2008, based on actual time served of 17 years, 2 months and 9 days, equivalent to legal 21 years, 5 months and 3 days, Bobbins was freed.[2][7][8] Vivian and Anders Hultman belatedly protested the release in media.[9]
On October 6, 2008, Raul M. Gonzalez confirmed Claudio Teehankee Jr.'s release from prison by virtue of President Gloria Macapagal-Arroyo' commutation of sentence: "Everything went by the rules here. His [Teehankee’s] records have been reviewed by the Board of Pardons and Parole before a recommendation was given to the President."[10] Raul M. Gonzalez further stated that: “I would assume that he already paid the civil liabilities.” Philippine Daily Inquirer reported about P15 million as total damages. NBP Supt. Ramon Reyes said Teehankee was released based on "good conduct time allowance," or GCTA: “The release of Mr. Teehankee underwent a rigorous review and it was signed by the Secretary of Justice, Raul Gonzalez.”[11][12]
On October 15, 2008, Atty. Ernesto Francisco, for Maureen Hultman, Roland John Chapman, and Jussi Olavi Leino, filed a 62-page certiorari petition with the Supreme Court of the Philippines against the Department of Justice (Philippines) and the Board of Pardons and Parole, to nullify Teehankee's granted executive clemency, commutation of sentence and release from detention. The petition alleged violation of the "Amended Guidelines for Recommending Executive Clemency" and Teehankee's failure to pay the amounts of P 2,050,000 to Chapman and the amounts of P4,148,369.84 and US$55,600 to Leino.[13] Secretary Raul M. Gonzalez earlier stated that the clemency has already “taken effect and it can’t be taken back unless there was fraud ... mathematical error and misapplication of rules. I don't think so. Otherwise, the Supreme Court will traverse the separation of powers."[14] The Supreme Court of the Philippines docketed the case as G.R. No. 184679 and required, on October 21, 2008, the public respondents and Teehankee, Jr. to file "Comment."[15]