This case has been cited 5 times or more.
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2011-11-16 |
SERENO, J. |
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| The dismissal of the criminal Complaint in this case for the crime of attempted rape did not necessarily foreclose the continuation of the administrative action or carry with it relief from administrative liability.[7] Yet, as the Prosecutor's Office has reconsidered its earlier findings with respect to acts of lasciviousness, the Court cannot help but be convinced that there was a breach in ethical standards committed by respondent when he kissed complainant. To be sure, this Court makes no finding whatsoever with respect to his criminal liability for acts of lasciviousness, which is properly lodged in the trial court proceedings. The Court's pronouncements in this administrative case are simply limited to evaluating the conduct of respondent as a court personnel. | |||||
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2008-04-23 |
CHICO-NAZARIO, J. |
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| Indeed, the well established rule is that the dismissal of the criminal case involving the same set of facts does not necessarily foreclose the continuation of the administrative action or carry with it relief from administrative liability.[59] The case of Tecson v. Sandiganbayan[60] provides elucidation on this very point, thus:[I]t is a basic principle of the law on public officers that a public official or employee is under a three-fold responsibility for violation of duty or for a wrongful act or omission. This simply means that a public officer may be held civilly, criminally, and administratively liable for a wrongful doing. Thus, if such violation or wrongful act results in damages to an individual, the public officer may be held civilly liable to reimburse the injured party. If the law violated attaches a penal sanction, the erring officer may be punished criminally. Finally, such violation may also lead to suspension, removal from office, or other administrative sanctions. This administrative liability is separate and distinct from the penal and civil liabilities. Furthermore, a finding of guilt in an administrative case may be sustained for as long as it is supported by substantial evidence that the respondent has committed the acts charged.[61] Substantial evidence is defined as that amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion.[62] On the other hand, criminal proceedings require a more stringent quantum of proof, which is proof beyond reasonable doubt. As defined under the law, proof beyond reasonable doubt does not mean such a degree of proof as, excluding the possibility of error, produces absolute certainty. Moral certainty only is required, or that degree of proof which produces conviction in an unprejudiced mind.[63] Hence, when Badiola was absolved from criminal liability, it simply meant that her guilt on the offenses she was charged with was not proven beyond reasonable doubt. This fact does not and should not in any way bind the outcome of the administrative case, which requires only substantial evidence to prove her administrative culpability. | |||||
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2008-01-29 |
NACHURA, J. |
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| At the outset, it must be stressed that this is an administrative case for dishonesty, grave misconduct, and falsification of official document. To sustain a finding of administrative culpability only substantial evidence is required, not overwhelming or preponderant, and very much less than proof beyond reasonable doubt as required in criminal cases.[12] Substantial evidence means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. | |||||
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2007-07-17 |
AUSTRIA-MARTINEZ, J. |
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| As to the findings of the Ombudsman, it is settled that in administrative proceedings, the quantum of proof required for a finding of guilt is only substantial evidence -- that amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion.[51] Factual findings of administrative bodies, when supported by substantial evidence, are entitled to great weight and respect on appeal.[52] And a finding of guilt in an administrative case would also have to be sustained for as long as it is supported by substantial evidence that respondent has committed the acts stated in the complaint or formal charge.[53] | |||||