The Supreme Court, in People v. Aleman, affirmed the conviction of Edwin Aleman for robbery with homicide, underscoring the competency of a deaf-mute witness to testify in court. This decision clarifies that individuals with disabilities, who can perceive and communicate their perceptions through qualified interpreters or other means, are not inherently disqualified from providing crucial eyewitness testimony. This ruling reinforces the principle that justice should be accessible to all, regardless of communication challenges, and ensures that the perspectives of individuals with disabilities are valued in legal proceedings.

Silent Witness, Loud Justice: Can a Deaf-Mute Testify to Murder?

In the heart of Quezon City, on a February evening, Ramon Jaime Birosel was fatally stabbed during a robbery. The prosecution’s case rested heavily on the testimony of Mark Almodovar, a deaf-mute eyewitness. The legal question before the Supreme Court was whether Almodovar’s disability rendered him incompetent to testify, potentially jeopardizing the conviction of the accused, Edwin Aleman. The Court had to consider the requirements for witness competency under Philippine law, specifically concerning individuals with communication disabilities. The case hinged on whether Almodovar could accurately perceive and effectively communicate his observations to the court, despite his inability to hear or speak.

The Revised Rules on Evidence, Rule 130, Section 20 states, “All persons who can perceive, and perceiving, can make known their perception to others, may be witnesses.” The Court emphasized that the ability to perceive and communicate, not the manner of communication, is the determining factor. A deaf-mute person can be a competent witness if they understand the oath, comprehend the facts, and can communicate their ideas through a qualified interpreter. This approach recognizes that communication can take various forms, including writing, sign language, and sketches. The crucial element is the ability to convey one’s perceptions accurately and reliably.

The Court relied on its earlier pronouncements in People v. Tuangco, where it held:

A deaf-mute is not incompetent as a witness. All persons who can perceive, and perceiving, can make known their perception to others, may be witnesses. Deaf-mutes are competent witnesses where they (1) can understand and appreciate the sanctity of an oath; (2) can comprehend facts they are going to testify on; and (3) can communicate their ideas through a qualified interpreter. x x x. (Citations omitted.)

Building on this principle, the Court examined the qualifications of the interpreter, Daniel Catinguil, who was a licensed professional from the Philippine Registry of Interpreters for the Deaf, with extensive experience in teaching and special education. The Court found Catinguil’s expertise sufficient to facilitate Almodovar’s testimony. This underscores the importance of having qualified interpreters who can accurately convey the testimony of individuals with disabilities.

The defense argued that Almodovar’s testimony was unreliable due to his inability to answer certain questions and the fact that he received assistance from the victim’s family. The Court dismissed these concerns, pointing out that minor inconsistencies are common, especially when a witness is a deaf-mute. The Court also noted that the assistance provided to Almodovar did not necessarily indicate bias or improper motive. What mattered most was that Almodovar positively identified Aleman in court and provided a credible account of the events he witnessed.

Furthermore, the Court highlighted that the medico-legal report corroborated Almodovar’s testimony. The report confirmed that the victim died from multiple stab wounds, which aligned with Almodovar’s account of the stabbing. This physical evidence significantly strengthened the prosecution’s case. The Court also emphasized that the positive testimony of a single credible witness is sufficient for conviction, especially when supported by physical evidence. This principle reinforces the idea that direct evidence, when credible, can outweigh other forms of evidence.

The defense also raised the issue of Almodovar’s failure to identify Aleman in a police line-up. The Court clarified that a police line-up is not essential for proper identification. The crucial factor is the witness’s positive identification of the accused in open court. In this case, Almodovar positively identified Aleman as the perpetrator during his testimony. The Court noted that even if there were inconsistencies in the line-up identification, the in-court identification was sufficient to establish Aleman’s guilt.

The Court underscored the trial court’s assessment of Almodovar’s credibility, which was affirmed by the Court of Appeals. Appellate courts generally defer to the trial court’s assessment of witness credibility, as the trial court has the opportunity to directly observe the witness’s demeanor. Unless there is a clear showing of error or abuse of discretion, the appellate court will uphold the trial court’s findings. This deference to the trial court’s findings reinforces the importance of the trial court’s role in evaluating evidence and determining the credibility of witnesses.

Having established Aleman’s guilt, the Court addressed the proper penalty for robbery with homicide under Article 294(1) of the Revised Penal Code, as amended. Since the crime was not attended by any aggravating circumstances, the Court imposed the penalty of reclusion perpetua, which was the lesser of the two indivisible penalties prescribed by law. The Court also increased the civil indemnity awarded to the victim’s heirs from P50,000.00 to P75,000.00, aligning it with the current standard for cases of murder. The Court also affirmed the award of moral damages and actual damages, as well as imposed a legal interest of 6% per annum on all monetary awards from the date of finality of the decision.

FAQs

What was the key issue in this case?	The primary issue was whether a deaf-mute person is competent to testify as a witness in court. The Supreme Court had to determine if Mark Almodovar’s disability disqualified him from providing eyewitness testimony.
What is the legal basis for allowing a deaf-mute person to testify?	The legal basis is found in the Rules of Court, which states that anyone who can perceive and communicate their perceptions can be a witness. The key requirement is the ability to understand the oath and communicate facts through a qualified interpreter.
What is the role of a sign language interpreter in such cases?	The sign language interpreter facilitates communication between the deaf-mute witness and the court. They ensure that the witness’s testimony is accurately conveyed and understood by all parties involved.
Why was the failure to identify the accused in a police line-up not a major issue?	The Court ruled that a police line-up is not essential for proper identification. What matters most is the positive identification of the accused by the witness in open court during their testimony.
What evidence corroborated the deaf-mute witness’s testimony?	The medico-legal report, which confirmed that the victim died from multiple stab wounds, corroborated Mark Almodovar’s testimony. This physical evidence aligned with his account of the events.
What is the penalty for robbery with homicide under the Revised Penal Code?	Under Article 294(1) of the Revised Penal Code, as amended, the penalty for robbery with homicide is reclusion perpetua to death. The specific penalty depends on the presence of any aggravating or mitigating circumstances.
How did the Court address the issue of damages in this case?	The Court increased the civil indemnity to P75,000.00 and affirmed the award of moral and actual damages. It also imposed a legal interest of 6% per annum on all monetary awards from the date of finality of the decision until fully paid.
What is the significance of this case for people with disabilities?	The case underscores the importance of inclusivity in the justice system. It ensures that individuals with disabilities are not automatically disqualified from participating in legal proceedings as witnesses.

The Supreme Court’s decision in People v. Aleman affirms the principle that disability should not be a barrier to justice. By recognizing the competency of deaf-mute witnesses, the Court ensures that the perspectives and experiences of individuals with disabilities are valued in legal proceedings. This ruling promotes a more inclusive and equitable justice system for all.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines vs. Edwin Aleman y Longhas, G.R. No. 181539, July 24, 2013