Title
Carpio vs. People
Case
G.R. No. 211691
Decision Date
Apr 28, 2021
Carpio convicted for illegal firearm discharge after firing at Clarion without intent to kill; alibi defense rejected, conviction upheld by Supreme Court.

Case Digest (G.R. No. 211691)

Facts:

Letlet Carpio, G.R. No. 211691, April 28, 2021, Supreme Court First Division, Zalameda, J., writing for the Court. Petitioner Letlet Carpio sought review of the Court of Appeals decision in CA‑G.R. CR No. 00891 (19 August 2013) affirming her conviction for illegal discharge of firearm under Article 254 of the Revised Penal Code. The respondent is the People of the Philippines; co-accused in the trial was Abadieza Gabelino.

On 28 February 2007 in Toril, Davao City, private complainant Rebecca Vencio‑Clarion alleged that petitioner, after uttering insulting words and upon Gabelino’s urging, fetched a gun and fired at her, missing and causing Clarion to drop to the ground; Clarion and another witness, Estrella Fuentes, identified petitioner as the person who shot and pointed the firearm. Fuentes testified she ran from her house (about 200 meters away), arrived quickly (estimating five minutes or less), and saw petitioner pointing a gun toward Clarion about 3.5 meters away. Petitioner and Gabelino were arraigned, pleaded not guilty, and posted bail.

Petitioner offered an alibi defense: she testified she was at the public market tending her mother’s stall and later at her mother’s house; witness Leticia Las corroborated her market attendance. Gabelino testified she was awakened by a noise, saw Clarion and her sons throwing stones at her roof, and alleged that the police suggested filing charges; Gabelino denied conspiring to shoot.

The Metropolitan Trial Court (MTCC) found petitioner and Gabelino guilty in a Decision dated 15 September 2009 and imposed an indeterminate penalty (minimum three months, eleven days arresto mayor; maximum up to prision correccional). The Regional Trial Court (RTC) affirmed petitioner’s conviction but acquitted Gabelino for failure of proof. On appeal, the Court of Appeals affirmed the RTC in a Decision dated 19 August 2013. Petitioner filed a Petition for Review on Certiorari with the Supreme Court challenging the CA’s affirmati...(Pro-only)

Issues:

  • Did the Court of Appeals correctly affirm petitioner’s conviction for illegal discharge of firearm under Article 254 of the Revised Penal C...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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