The Supreme Court has specified that "the requirement that the dwelling house or sleeping apartment broken into be that of someone other than the defendant was an element of burglary at common law and is implicitly incorporated in N.C.G.S. 14-51." State v. Harold, 312 N.C. 787, 791, 325 S.E.2d 219, 222 (1985). "It is incumbent upon the State to produce substantial evidence tending to show that the premises broken into is the dwelling house of another." Id. at 792, 325 S.E.2d at 222. Indeed, at least three North Carolina cases have focused on the requirement that a breaking and entering must occur on property "of another" to constitute a burglary. In Harold, the defendant and his former girlfriend had purchased a house and lived in it together until the week before he murdered her. Harold, 312 N.C. at 789-90, 325 S.E.2d at 221. The defendant was convicted of first degree burglary, and also first degree murder based on premeditation and deliberation. He argued that the jury instructions should not have read "without her consent" and that they should have required a finding that he had no ownership interest in the house to permit a burglary conviction. Id. at 791, 325 S.E.2d at 222. Our Supreme Court stated that the defendant's emphasis on ownership was "misplaced," explaining that "the reason for prohibiting the offense of first degree burglary 'is to protect the habitation of men, where they repose and sleep, from meditated harm.'" Id. (quoting State v. Surles, 230 N.C. 272, 275, 52 S.E.2d 880, 882 (1949)). The Harold Court held that the evidence was sufficient to find the residence to be a "dwelling house of another," where the victim had lived in the house for five months preceding her death and had occupied the house when she was murdered. Harold, 312 N.C. at 792, 325 S.E.2d at 222.