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gained approximately 50 pounds before trial)]; Jackson [ v. State, 316 Ga.App. 80, 729 S.E.2d 404 (May 30, 2012) (permitting identification testimony when most of perpetrator's face was obscured in surveillance video but witness testified that she identified the defendant by her familiarity with his walk and clothing).].” 2. Evidence improperly admitted where not based on any factor inaccessible to jury. “[A] witness's familiarity with the defendant, in and of itself, ‘does not make his or her identification testimony based on a video or photograph admissible.’ Grimes [ v. State , 291 Ga. App. 585, 591(2) (662 S.E.2d 346) (2008)]. And here, there was no evidence that the perpetrator's face was obscured by a mask or that Owens's appearance had changed prior to trial. Although the State argues that the perpetrator in the surveillance video wore sunglasses and a hat, we have rejected a similar argument in the past, see id. … and the [defendant’s] probation officer did not offer any basis for her identification of Owens aside from general familiarity.” Viability of this line of cases questioned, New case!Patch v. State , A16A0524, ___ Ga.App. ___, ___ S.E.2d ___, 2016 WL 3060019 (May 26, 2016) ( quoting Ronald L. Carlson and Michael Scott Carlson, Carlson on Evidence, p. 417 (4 th ed., 2016) (‘Federal Evidence Rule 701, newly embraced in Georgia as part of the 2013 evidence code, permits a wide range of opinions by lay witnesses.’).” Mitchell v. State, 283 Ga.App. 456, 641 S.E.2d 674 (February 6, 2007). “[T]he trial court erred when it allowed a witness to identify Mitchell in two photographs introduced into evidence by the state.” Follows Carter (March 31, 2004), below. Distinguishes Smith v. State , 247 Ga. 612, 277 S.E.2d 678 (1981) (expert opinion on identification is admissible): “ Smith deals only with expert testimony, which is admissible ‘where the conclusion of the expert is one which jurors would not ordinarily be able to draw for themselves; i.e., the conclusion is beyond the ken of the average layman,’” unlike this case, where the police officer was not testifying as an expert. “[A] lay witness’s testimony concerning an identification should be admitted for the jury’s consideration only ‘if there is some basis for concluding that the witness is more likely to correctly identify the defendant from the photograph than is the jury[, as when] the witness is ‘familiar with the defendant’s appearance around the time [a] surveillance photograph was taken and the defendant’s appearance has changed prior to trial,’ (Citation omitted.) Bradford v. State, 274 Ga.App. 659, 659-661(3) (618 S.E.2d 709) (2005), or when the witness knows about some other distinctive but presently inaccessible characteristic of the defendant’s appearance. Id. at 661(3) (affirming admission of testimony by store owner and former employer identifying defendant as the person on videotape of store robbery on the basis of his distinctive body movements).” Convictions reversed. Accord, Rogers v. State , 294 Ga.App. 195, 670 S.E.2d 106 (October 22, 2008) (trial court erred in allowing officer to identify defendant in video, absent “a basis for concluding that [officer] was more likely to identify Rogers correctly than was the jury.”); Bryson v. State , 316 Ga.App. 512, 729 S.E.2d 631 (June 29, 2012) (same as Rogers , but harmess). Quedens v. State, 280 Ga. 355, 629 S.E.2d 197 (March 27, 2006). Trial court erred in allowing victim’s son to testify to an opinion that the skeletal remains were his father’s, but error harmless in light of overwhelming evidence of guilt. “A lay witness may give an opinion based upon the witness’s personal observation and experience if the matter is one within the scope of the average juror’s knowledge. Weston v. State, 276 Ga. 680(3) (580 S.E.2d 204) (2003). With regard to skeletal remains, a lay witness may identify skeletal remains as those of a certain person where the lay witness can establish personal knowledge of an unusual factor peculiar to the skeletal remains themselves . See, e.g., McVeigh v. State, 205 Ga. 326 (53 S.E.2d 462) (1949) (victim's brother identified skeletal remains as those of his missing brother because of a dental filling contained in the skull that the witness had seen filled by a dentist); Gray v. Commonwealth, 101 Pa. 380 (1882) (daughter and a good friend of the victim were permitted to identify a skull and jawbone as that of the victim based on certain peculiarities of the jaw and mouth). In the case at bar, the witness’s testimony underlying his identification of the remains was not based on something peculiar to the remains themselves, but was based on the circumstances in which the remains were found: the generic pair of pants in which the remains were found, the presence of lip balm in the pants’ pocket, and the presence in the well of dentures which were not otherwise linked to the witness’s father . Since the witness’s opinion that the remains were undoubtedly those of his father was not based on factors peculiar to the remains, the admission of his opinion was inappropriate.” Brown v. State, 278 Ga. 369, 602 S.E.2d 834 (September 13, 2004). Although she didn’t see the assailant, victim testified that she recognized defendant’s voice in the next room of her house because “Brown had telephoned the [victim’s] home ‘numerous’ times to talk to [victim’s daughter] and had identified herself. [Victim] testified that Brown had a ‘distinctive voice,’ and ‘the minute I heard that, I knowed (sic) who that voice belonged to.’” Held, this evidence was properly admitted. “‘(A)lthough voice identification testimony is generally considered to be direct evidence (cits.), Georgia courts have construed such testimony to be opinion evidence, which, of course, is inadmissible unless the witness discloses the basis for his opinion.’ Shepherd v. State, 173 Ga.App. 499, 500-501(1) (326 S.E.2d 596) (1985). In addition, ‘proof of telephone conversations may be admissible in evidence when the identity of the person against whom the conversation is sought to be admitted is established by circumstantial as well as direct evidence.’ Constantino v. State, 243 Ga. 595,