This case has been cited 2 times or more.
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2011-10-05 |
BRION, J. |
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| The fact that the respondents had previously been found administratively liable, based on the same set of facts, does not necessarily make them the "most guilty." An administrative case is altogether different from a criminal case, such that the disposition in the former does not necessarily result in the same disposition for the latter, although both may arise from the same set of facts.[82] The most that we can read from the finding of liability is that the respondents have been found to be administratively guilty by substantial evidence - the quantum of proof required in an administrative proceeding. The requirement of the Revised Rules of Criminal Procedure (which RA No. 6770 adopted by reference) that the proposed witness should not appear to be the "most guilty" is obviously in line with the character[83] and purpose[84] of a criminal proceeding, and the much stricter standards[85] observed in these cases. They are standards entirely different from those applicable in administrative proceedings. | |||||
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2011-09-14 |
MENDOZA, J. |
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| It is a basic rule in administrative law that public officials are under a three-fold responsibility for a violation of their duty or for a wrongful act or omission, such that they may be held civilly, criminally and administratively liable for the same act.[37] Obviously, administrative liability is separate and distinct from penal and civil liability.[38] In the case of People v. Sandiganbayan,[39]the Court elaborated on the difference between administrative and criminal liability: The distinct and independent nature of one proceeding from the other can be attributed to the following: first, the difference in the quantum of evidence required and, correlatively, the procedure observed and sanctions imposed; and second, the principle that a single act may offend against two or more distinct and related provisions of law, or that the same act may give rise to criminal as well as administrative liability.[40] | |||||