CASE No.

People of the Philippines vs. Adel Tuangco, et. Al.

GR. No. 130331, November 22, 2000

Doctrine (Qualification and Competency of Witnesses and Testimony Rule 130 Section
20):

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.

Facts:

Petitioner Caran

Issue:

Whether or not the contention of the petitioner that the testimony of the private respondent is
self-serving hence, should not be admissible is proper.

Ruling:

The Court affirmed the ruling of the CAR, stating that “The law itself provide that a party or any
other person interested in the outcome of the case may testify. The testimony of an interested
witness, this Court has said, should not be rejected on the ground of bias alone, and must be
judged on its own merits, and if such testimony is clear and convincing and not destroyed by
other evidence on record, it may be believed.”. Also, it stated that the testimony of the private
respondent is not self-serving since a self-serving evidence is an evidence made by a party
out of court at one time; it does not include a party’s testiony as a witness in court.