PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs.

ADEL TUANGCO,
NELSON PINEDA, JR. and SONNY TUANGCO, accused. ADEL TUANGCO and
SONNY TUANGCO , accused- appellants.

Facts

Appellants Tuangco, who are brothers, and accused Nelson Pineda, Jr. were charged
and convicted with rape with homicide and theft in connection with the death of Aurea
Eugenio and loss of her personal effects. Aurea was found dead naked, with nine stab
wounds on her neck and bloodied genitalia showing signs of sexual abuse. Their
conviction was principally based on the testimony of Silvestre Sanggalan, a deaf-mute.
His testimony was interpreted by Eva Sangco, a sign language interpreter with 22 years
teaching experience at the Philippine School for the Deaf and who had been exposed in
t.v. programs and had testified in five previous court proceedings. Appellants who
pleaded not guilty and interposed alibi appealed to this Court challenging the testimony
of the deaf- mute eyewitness claiming that "he could not truthfully and convincingly
convey what really transpired on that fateful night".

Issue

Whether or not the trial court gravely erred in giving full faith and credence to the
alleged eyewitness account of silvestre sanggalan who is a deaf-mute and unschooled

Held

The Court ruled that a deaf-mute is competent to testify as long as he can understand
and appreciate the sanctity of an oath, can comprehend facts that he is going to testify
and can communicate their ideas through a qualified interpreter; that the appellate
court will not review the method adopted by the interpreter in the absence of a
showing that the complaining witness was in some way injured by reason of the
particular method adopted; that alibi must yield to positive identification; and that
findings of the trial court on credibility of witnesses are not disturbed on appeal.