The Mabit in his sefer Beis Elokim (Sha’ar Tefillah, Perek 6) asks a strong question on the episode of Moshe Rabbeinu.
The Gemara in Berachos (31a) writes: “It is forbidden for one to raise his voice when davening”. We learn this from Chanah, where the pasuk says, וקולה לא ישמע – “Her voice couldn’t be heard”. Similarly, another Gemara in Berachos (24b) teaches: “One who raises his voice when davening is considered to have little emunah [faith], and one who raises his voice when davening is considered to be a false prophet”. The Mabit explains: Hashem’s presence is everywhere, and if one shouts when davening it gives off the impression that he believes Hashem can’t hear him if he davens quietly, and that he doesn’t think Hashem is everywhere.
The Mabit then writes: “You are going to ask from that which we find in many places that people daven with an expression of צעקה, which means raising the voice, like we find by Moshe (Shemos 8:8) “Moshe screamed out to Hashem over the matter of the frogs”. Similarly, we find, “Klal Yisroel screamed out to Hashem” (Shemos 14:10), and “Moshe screamed out to Hashem, G-d please heal her” (Bamidbar 12:13), and “We screamed out to Hashem, and He listened to our voice” (Bamidbar 20:16) and many other places in Tanach?”
The Mabit answers: “We can answer, that tefillos that we say everyday, not at a time of distress, those tefillos should not be said loud, as we are able to concentrate when davening quietly. However, tefillos that we recite at times of distress and pain, it’s not possible for one to daven calmly, as he is in great pain, therefore, one shouts out with a loud voice, to show that he recognizes and feels that the pain he is going through comes from Hashem, and there is no one else who can help besides Him. So was the tefillah of Moshe Rabbeinu by the frogs. Pharoah told Moshe ‘Daven to Hashem ... and I will send out the people etc.’ This was the first time Moshe heard Pharaoh offering to send out the Yidden, and he felt that the freeing of the Jews was incumbent upon this tefillah of removing the frogs, therefore, he screamed out to Hashem.”
We can ask on the Mabit. What question and proof is there from Moshe Rabbeinu, perhaps the reason he screamed out was because of the din that one must be able to hear the words of his davening? It must be, that the Mabit holds that as long as one recites the words loud enough that in a normal situation they could be heard, it’s enough, and we aren’t concerned about the fact that in this particular scenario the words can’t be heard. Therefore, he asks what he asks and answers what he answers. According to the Mabit, it would come out that if one is at a chasunah with loud music he would be able to recite krias shema, birchas hamazon and shemonah esrei.
R’ Chaim Kanievsky Refutes Any Proof from Moshe Rabbeinu and Understands that the Expression of Zeakah Is Simply a Certain Type of Tefillah
R’ Zilberstein brings the R’ Chaim Kanievsky held that there is no proof from Moshe Rabbeinu. He brings the Yalkut Shimoni (Vo’eschanon, remez 811) which says that there are ten expressions of tefillah, and one of them is צעקה, therefore, it is likely that Moshe Rabbeinu never screamed and raised his voice, rather he davened a certain special type of tefillah.
We find in Shmuel (1, 15:11): ויזעק אל ה' כל הלילה - “They cried out to Hashem the entire night” – Is it possible for a person to scream with a loud voice the entire night? No, rather we see from here that זעקה is at type of tefillah, and the reason it is referred to as, זעקה, is because it comes from the depths of the heart, however, it doesn’t refer to screaming with a loud voice.
Based on the above, we have no proof from Moshe Rabbeinu. In fact, if there is a loud outside noise one can read krias shema and it’s considered that one can hear the words, as even Moshe Rabbeinu himself when davening by the Plague of the Frogs never shouted in a loud voice – rather, he davened a special type of tefillah, which came from the depths of his heart. Therefore, R’ Zilberstein concludes, that bedieved one can fulfil his duty when reciting krias shema, berachos, shemonah esrei etc. in such a situation and there is no need to repeat. He then cites that the sefer “Leket HaKemech HaChodosh” also concludes like this.
