G.R. No. 91787 - Terminal Facilities and Services Corp. vs. National Labor Relations Commission

The case involves multiple accused originally charged with “robbery with double homicide and double frustrated homicide” – namely Edmundo Macarubbo (alias Dummun), Melencio Battung (alias Melis, who remains at large), Crisostomo Saquing (alias Timoy), Macario Corpuz (alias Cario), and Antonio Saquing (alias Tonio).
Earlier proceedings involved the withdrawal of pleas by Crisostomo Saquing, Macario Corpuz, and Edmundo Macarubbo who subsequently pleaded guilty and were sentenced to life imprisonment.
This case specifically focuses on 46-year-old Antonio Saquing, father of Crisostomo Saquing, whose defense and participation are under scrutiny.

On October 23, 1961, a group posed as Philippine Constabulary soldiers visited the home of spouses Florentino Guerra and Gavina Burgos Guerra in Barrio Alba, Baggao, Cagayan, under the pretext of inspecting firearms.
Initially welcomed into the home, the visitors engaged in conversation, shared coffee and dinner, and later expressed a desire to examine the shotgun of Florentino Guerra.
After a brief outing to the nearby residence of Victorio Ramos, where additional inquiries about firearms were made, the group reconvened at the Guerra household.
The deception was unveiled when the group revealed their true identity as bandits (tulisan), tying up members of the household and demanding money.
The culprits ransacked the home, extracting a minimal amount from Florentino Guerra and seizing additional valuables that eventually totaled P862.50, comprising cash, a shotgun, ammunition, and assorted articles.

The bandits tied and gagged several occupants, including both male and female residents, and then herded nine of the victims into the yard of the house.
Among these victims were Florentino Guerra, Antonio Cacayan, Emiliano Leones, and Santos Umicay. A rope was used to tie the hands of the victims together in pairs, thereby restricting any possibility of escape.
The group then transported the victims to a secluded, forested area at the foot of a hill — a location about one kilometer away from the Guerra residence and 200 meters from the nearest house.
In this isolated setting, the victims were forced to lie face down; subsequently, Antonio Cacayan, Florentino Guerra, Santos Umicay, and Emiliano Leones were hacked with a sharp-bladed weapon.
The heinous actions culminated with at least two victims (Antonio Cacayan and Florentino Guerra) sustaining fatal injuries, while the others suffered injuries that were not life‑threatening.
As the victims struggled, some managed to untie themselves and escape into the forest, though one victim died at the scene and another succumbed later while being transported.

Antonio Saquing played a pivotal role in the commission of the crime. He took possession of the firearm (a sidearm) and acted as the guard over the tied-up victims.
His function during the crime was not passive; he was actively involved from the deception (posing as a constabulary officer) to ensuring that the victims did not escape, by holding the gun and issuing warnings.
In his defense, Antonio Saquing claimed an alibi stating that he did not leave his house in Barrio Cattaran, Solana, Cagayan on the day of the crime because he suffered from a pimple on his right abdomen that allegedly induced unconsciousness.
This alibi was rebutted by multiple eyewitnesses such as Inocencio Balanay, Emiliano Leones, and Gavina Burgos Guerra, who all positively identified him and noted his continuous presence at the scene.
Physical evidence, including the nature of a scar on his abdomen (described as an elongated zigzag scar indicative of suturing from a shotgun injury), further weakened his alibi claim.

The perpetrators, including Antonio Saquing, used a false representation by impersonating Philippine Constabulary soldiers, thereby gaining undue trust from the victims.
The crime was perpetrated in a dwelling, enhancing its gravity, and the subsequent transfer of victims to a secluded, uninhabited area contributed to the treacherous nature of the conduct.
The comprehensive nature of the crime — involving deception, robbery, binding of victims, and execution at a remote location — established the elements constituting robbery with homicide.
The recovered booty and the record of injuries, including autopsy findings confirming lethal bolo wounds in critical anatomical locations of the deceased victims, cemented the causal connection between the robbery and the homicides.

Whether Antonio Saquing’s claim that he remained at home due to an incapacitating pimple could be sustained in light of contrary physical evidence (i.e., a sutured wound) and eyewitness identifications.
Whether the inconsistencies in his alibi undermine its reliability.

Whether Antonio Saquing’s conduct (seizing the firearm and guarding the victims) constitutes principal participation rather than mere accessory involvement.
The significance of his active role in the orchestration and completion of the robbery that escalated to homicide.

Whether the crime should be charged as “robbery with double homicide” or simply as “robbery with homicide,” considering the merging of the homicidal acts committed on the same occasion.
How the legal interpretation of “homicide” in the context of robbery affects the proper categorization of the offense.

Whether the use of craft — specifically impersonating law enforcement officers — and the selection of a dwelling and secluded, uninhabited area as the scene of the crime, warrant the imposition of the death penalty.
Whether treachery, as exhibited by tying the victims and leaving them helpless, further aggravates the offense to justify the enhanced penalty.