PEOPLE v CRISOLOGO G.R. No.

74145 (1987)
224 Automatic Review of Death sentence reversed, accused acquitted
EB, Padilla
An information for robbery with homicide was file against Zosimo Crisologo, a
deaf-mute. During arraignment, the accused was allegedly informed of the charge
against him through sign language and he subsequently entered a plea of guilty. Upon
objection of counsel, however, this plea was disregarded and arraignment was
rescheduled until the Court could avail of an expert in sign language from the school of
the deaf and dumb.
Almost 6 years later, there was still no sign language expert. The accused then
waived the reading of the information and pleaded not guilty. Trial proceeded without
evidence being presented on his part and without a sign language expert ever being
utilized at any stage of the proceedings. Accused was found guilty and sentenced to die
by electrocution.
WON the accuseds right to due process was violated on account of the lack of a sign
language expert. YES

The absence of an interpreter in sign language who could have conveyed to the
accused, a deaf-mute, the full facts of the offense with which he was charged and who

could also have communicated the accused's own version of the circumstances which
led to his implication in the crime, deprived the accused of a full and fair trial and a
reasonable opportunity to defend himself. Not even the accused's final plea of not guilty
can excuse these inherently unjust circumstances.

The absence of a qualified interpreter in sign language and of any other means,
whether in writing or otherwise, to inform the accused of the charges against him
denied the accused his fundamental right to due process of law. The accuracy and
fairness of the factual process by which the guilt or innocence of the accused was
determined was not safeguarded. The accused could not be said to have enjoyed the
right to be heard by himself and counsel, and to be informed of the nature and cause of
the accusation against him in the proceedings where his life and liberty were at stake.

* Aside from the unfair setting and circumstance in which the accused was convicted,
insufficiency of evidence to warrant a finding of guilty beyond reasonable doubt also
leads this Court to set aside the conviction.