Yes. If it is sufficiently original to be a distinct work (most human translations will be), it is a derivative work with its own copyright; if it is, e.g., a purely mechanical translation, it is covered by the copyright on the original.
In either case, without permission or a copyright exception (e.g., fair use) it is also a violation of the original copyright, either as a derivative work or a copy.
IANAL, but my understanding is "yes, that would be considered a derived work". Of course, it really only matters if you expect to end up in court over it.
Translating ancient programs like this are unlikely to trigger a legal case, but I would not rule it out entirely in this day and age.
