DEAF-MUTE WITNESS:

     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. (People vs. Hayag, 101 SCRA 67). Thus, in People vs. De Leon, 50 Phil. 539 and People vs. Sasota, 52 Phil. 281, the accused was convicted on the basis of the testimony of a deaf-mute.  Although in People vs. Bustos, 51 Phil 389, the testimony of a deaf-mute was rejected, this was because there were times during his testimony that the interpreter could not make out what the witness meant by the signs she used.

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