Carpio v. People
REITERATIONFacts
The Antecedents: Petitioner Carlos Carpio, a Barangay Chairman, was accused of Violation of Domicile under Article 128 of the Revised Penal Code for allegedly entering the dwelling of Corazon Abalos without consent and conducting an illegal search. The indictment stated that on March 13, 1982, Carpio entered Abalos' residence purportedly looking for a certain "Mundong." Corazon Abalos testified that Carpio entered her house unannounced and without a warrant. Procedural History: The Sandiganbayan found petitioner guilty beyond reasonable doubt and sentenced him to an indeterminate penalty. The Sandiganbayan relied solely on the testimony of Corazon Abalos. The Petition: Petitioner seeks reversal of the Sandiganbayan decision, arguing that his conviction was based on the sole, unreliable testimony of the complainant, which was contradicted by defense evidence.
Issue(s)
Whether the testimony of Corazon Abalos, as the sole basis for conviction, is sufficient to establish guilt beyond reasonable doubt, considering its contradictions and lack of credibility. Whether the evidence presented by the defense, including the testimony of Sgt. Rodolfo Perez, sufficiently contradicts the complainant's testimony and raises reasonable doubt, particularly regarding the alleged illegal entry and search.
Ruling
The Supreme Court reversed and set aside the decision of the Sandiganbayan, acquitting petitioner Carlos Carpio of the offense charged.
Ratio Decidendi
On Issue 1: The Supreme Court held that while a conviction may rest on the testimony of a single witness, that witness must be trustworthy and reliable. In this case, Corazon Abalos' testimony was found to be insufficient for conviction because her evidence was contradicted by the proofs of the defense, including the testimony of impartial persons. Furthermore, her testimony made no sense, as it described a search for a friend of her husband and an illegal entry into her house for that purpose by the barangay chairman, who had no conceivable reason for doing so on that day. The Court considered her accusation a concocted one, designed to counteract the petitioner's complaint against Pat. Enrico Cruz, who is her brother-in-law and on whom she and her husband rely for subsistence. On Issue 2: The defense presented evidence, including the testimony of Sgt. Rodolfo Perez, which corroborated petitioner's account of the events. Sgt. Perez testified that he responded to a call for police assistance and found a riot in progress. He saw damage to petitioner's house and was led to Corazon Abalos' place to find "Mundong." He stated that they did not enter Corazon Abalos' house and that he advised petitioner to lodge a complaint. This testimony, from a witness not shown to have any motive to falsify, directly contradicted Corazon Abalos' claim of an illegal entry and search by Carpio. The Sandiganbayan itself noted that Sgt. Perez's testimony corroborated Carpio's evidence.
Main Doctrine
The testimony of a single witness, to be sufficient for conviction, must be trustworthy and reliable. Where the testimony of the complaining witness is contradicted by defense evidence, including that of impartial witnesses, and appears inherently improbable, it should not be given credence.