Wednesday, April 20, 2016

Substantial evidence



OFFICE OF THE COURT ADMINISTRATOR, COMPLAINANT, VS. PRESIDING JUDGE JOSEPH CEDRICK O. RUIZ, REGIONAL TRIAL COURT, BRANCH 61, MAKATI CITY, RESPONDENT

“x x x.

We reiterate that only substantial evidence is required to support our conclusions in administrative proceedings.⁠16 Substantial evidence is that amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion. The standard of substantial is satisfied when there is reasonable ground to believethat the respondent is responsible for the misconduct complained of, even if such might not be overwhelming or even preponderant.⁠17 That the respondent committed acts constituting malversation or violations of the Anti-Graft and Corrupt Practices Act should be adjudged in the same manner that other acts classified as serious charges under Rule 140 (such as bribery, immorality, gross misconduct, dishonesty, and partisan political activities) should be weighed — through substantial evidence.⁠18 Expressed from the point of view of criminal law, evidence to support a conviction in a criminal case is not necessary in an administrative proceeding like the present case.

The Sandiganbayan, in considering the respondent’s guilt in the criminal case before it, gave full probative value to the testimonies of Fatima Ruda (OlC-City Budget Officer), Jose R. Torres (OlC-City Treasurer), Glendora Deloria (City Accountant), and Pepe Nortal (Police Inspector of the Dapitan City Police). These conclusions and approach do not mean that we shall not examine, on our own in the present proceedings, the evidence on record before us.

X x x.”