This case has been cited 1 times or more.
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2007-07-30 |
CHICO-NAZARIO, J. |
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| First, the quantum of evidence required in an administrative case is less than that required in a criminal case.[34] Criminal and administrative proceedings may involve similar operative facts; but each requires a different quantum of evidence. Administrative cases require only substantial evidence, or such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.[35] In contrast, in Criminal Case Nos. 99-525 to 99-531, respondents are required to proffer proof beyond reasonable doubt to secure petitioner's conviction. Rule 133 of the Revised Rules on Evidence provides:Sec. 2. Proof beyond reasonable doubt. - In a criminal case, the accused is entitled to an acquittal, unless his guilt is shown beyond reasonable doubt. Proof beyond reasonable doubt does not mean such a degree of proof as, excluding possibility of error, produces absolute certainty. Moral certainty only is required, or that degree of proof which produces conviction in an unprejudiced mind. Thus, considering the difference in the quantum of evidence, as well as the procedure followed and the sanctions imposed in criminal and administrative proceedings, the findings and conclusions in one should not necessarily be binding on the other.[36] Notably, the evidence presented in the administrative case may not necessarily be the same evidence to be presented in the criminal cases. The prosecution is certainly not precluded from adducing additional evidence to discharge the burden of proof required in the criminal cases. Significantly, the prosecution had manifested that it would present testimonial evidence which was not presented in the administrative case. | |||||