G.R. No. L-38635 November 17, 1980
The People of the Philippines, plaintiff-appellee, vs. Daniel Hayag, accused-appellant.

FACTS

Daniel Hayag appealed his conviction for rape and life sentence by the Court of First Instance of Davao del Norte. The case involved the alleged rape of Esperanza Ranga, a 32-year-old deaf-mute farm girl. Hayag admitted to having sexual intercourse with Esperanza nine times between 1970 and December 4, 1972, in Carmen, Davao del Norte. The central dispute was whether the intercourse on October 26, 1972, was rape or consensual. The prosecution’s case rested entirely on Esperanza’s testimony, communicated through sign language interpreted by her sister, Virginia Ranga, a public school teacher and college graduate. No medical examination was conducted immediately after the alleged October 26 incident, and the only corroborative evidence was a hospital certificate dated December 7, 1972, indicating Esperanza was pregnant. The defense strongly objected to Virginia acting as interpreter, arguing she was biased, having signed the complaint herself, and lacked the neutrality of a third-party interpreter. With no instructor from a school for deaf-mutes available, the trial court proceeded with Virginia as the sole interpreter.

ISSUE

The main issue is whether the testimony of the deaf-mute victim, as interpreted by her sister, is sufficiently credible and reliable to sustain a conviction for rape beyond a reasonable doubt.

RULING

The Supreme Court reversed the conviction and acquitted Daniel Hayag on the ground of reasonable doubt. The Court acknowledged the general competence of deaf-mutes as witnesses and the trial court’s discretion in selecting an interpreter. However, it emphasized that the reliability of the interpretation is paramount. In this case, the conviction was based exclusively on the victim’s story as conveyed by her sister, Virginia, who was not a disinterested party. The Court contrasted this with prior rape convictions involving deaf-mute victims, which were supported by interpreters from schools for deaf-mutes and corroborative evidence. Here, the lack of an impartial interpreter and the absence of any corroboration created serious doubt. The Court noted the victim’s delayed reporting of the incident—confiding in her mother 40 days later—and inconsistencies in the mother’s own testimony regarding the number and date of the rapes. Furthermore, the Court found the circumstances of the alleged rape in an open field, without a weapon and against a physically capable adult, cast doubt on the claim of effective resistance. Given these factors, the prosecution’s evidence was deemed insufficient to prove guilt beyond a reasonable doubt.