G.R. No. L-64349 May 27, 1988
CARLOS CARPIO, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.

FACTS

Petitioner Carlos Carpio, the Barangay Chairman of Barrio Slip Zero, Kagitingan Extension, Tondo, Manila, was convicted by the Sandiganbayan of Violation of Domicile under Article 128 of the Revised Penal Code. The charge stemmed from an incident on March 13, 1982, where he allegedly entered the dwelling of Corazon Abalos without a warrant or consent to search for a certain “Mundong.” The prosecution relied solely on the testimony of Corazon Abalos, who claimed Carpio forced his way into her home.
The defense presented a different narrative. The record shows that on March 14, 1982, Carpio, in his official capacity, publicly admonished Corazon’s husband, Reynaldo Abalos, for brandishing a bolo. Later that day, a group including Reynaldo, a man named “Mundong,” and others, allegedly abetted by Patrolman Enrico Cruz (Corazon’s brother-in-law), destroyed Carpio’s store and house. Carpio, with police assistance from Sgt. Rodolfo Perez, then went to the Abalos residence to arrest those responsible but was refused entry. Corazon Abalos filed her complaint for violation of domicile only after these events and after Carpio had filed an administrative complaint against Patrolman Cruz.

ISSUE

Whether the Sandiganbayan erred in convicting petitioner Carlos Carpio of Violation of Domicile based solely on the uncorroborated testimony of the private complainant.

RULING

Yes. The Supreme Court reversed the conviction and acquitted Carlos Carpio. The Court held that while a conviction can rest on the testimony of a single witness, such testimony must be credible, trustworthy, and reliable. The testimony of Corazon Abalos failed to meet this standard. Her account was not only uncorroborated but was also directly contradicted by the defense evidence, including the impartial testimony of Sgt. Rodolfo Perez, who corroborated that the police visit to the Abalos residence on March 14 was a legitimate follow-up operation after the attack on Carpio’s property and that they did not illegally enter the house.
The Court found the complainant’s testimony inherently illogical, as it described a barangay chairman entering a home without any apparent motive on March 13, a day before the hostile events that would have provided a context for any police action. The timing of the complaint, filed only after Carpio initiated an administrative case against her brother-in-law, Patrolman Cruz, upon whom she and her husband relied for support, strongly suggested the charge was a fabricated retaliatory measure. Therefore, the prosecution failed to prove Carpio’s guilt beyond reasonable doubt.