This case has been cited 9 times or more.
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2013-06-18 |
VILLARAMA, JR., J. |
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| Administrative proceedings are governed by the "substantial evidence rule." A finding of guilt in an administrative case would have to be sustained for as long as it is supported by substantial evidence that the respondent has committed the acts stated in the complaint or formal charge. As defined, substantial evidence is such relevant evidence as a reasonable mind may accept as adequate to support a conclusion.[27] We find that Marquez and Verdillo failed to present any cogent reason for the Court to deviate from the rule that factual findings of administrative agencies are generally held to be binding and final so long as they are supported by substantial evidence in the record of the case. | |||||
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2012-08-23 |
DEL CASTILLO, J. |
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| To us, the discrepancy between the "audit sales" and the actual amount remitted by petitioner is sufficient evidence of dishonesty and grave misconduct warranting his dismissal from public service. We need not belabor the point that unlike in a criminal case where proof beyond reasonable doubt is required, administrative proceedings only require substantial evidence or "such relevant evidence as a reasonable mind may accept as adequate to support a conclusion." [62] | |||||
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2009-06-04 |
PER CURIAM |
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| Lastly, the Court does not agree with the finding of the Office of the Court Administrator in its first Report dated June 13, 2006 recommending that the Investigation Report of Investigating Judge Dumdum be set aside and that the complaint be investigated anew since Canque was not informed of her right to be heard by herself and counsel during the investigation - an omission allegedly amounting to a denial of her right to due process. The essence of due process is that a party be afforded a reasonable opportunity to be heard and to present any evidence he may have in support of his defense. Technical rules of procedure and evidence are not strictly applied to administrative proceedings. Thus, administrative due process cannot be fully equated with due process in its strict judicial sense.[13] A formal or trial-type hearing is not required. | |||||
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2008-08-22 |
BRION, J. |
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| Forum shopping is the act of a litigant who "repetitively availed of several judicial remedies in different courts, simultaneously or successively, all substantially founded on the same transactions and the same essential facts and circumstances, and all raising substantially the same issues either pending in or already resolved adversely by some other court to increase his chances of obtaining a favorable decision if not in one court, then in another."[17] It is directly addressed and prohibited under Section 5, Rule 7 of the 1997 Rules of Civil Procedure, and is signaled by the presence of the following requisites: (1) identity of parties, or at least such parties who represent the same interests in both actions, (2) identity of the rights asserted and the relief prayed for, the relief being founded on the same facts, and (3) identity of the two preceding particulars such that any judgment rendered in the pending case, regardless of which party is successful, would amount to res judicata in the other.[18] In simpler terms, the test to determine whether a party has violated the rule against forum shopping is where the elements of litis pendentia are present or where a final judgment in one case will amount to res judicata in the other.[19] | |||||
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2008-04-23 |
CHICO-NAZARIO, J. |
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| [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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2007-07-04 |
CHICO-NAZARIO, J. |
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| The Court has laid down the yardstick to determine whether a party violated the rule against forum shopping, as where the elements of litis pendentia are present or where a final judgment in one case will amount to res judicata in the other. Stated differently, there must be between the two cases: (a) identity of parties; (b) identity of rights asserted and reliefs prayed for, the relief being founded on the same facts; and (c) the identity of the two preceding particulars is such that any judgment rendered in the other action will, regardless of which party is successful, amount to res judicata in the action under consideration.[27] | |||||
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2007-04-27 |
QUISUMBING, J. |
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| As for the petitioner's allegation of lack of due process, we stress that in administrative proceedings, due process simply means an opportunity to seek a reconsideration of the order complained of; it cannot be fully equated to due process in its strict jurisprudential sense. A respondent in an administrative case is not entitled to be informed of the preliminary findings and recommendations; he is entitled only to a reasonable opportunity to be heard, and to the administrative decision based on substantial evidence.[23] Note that it is the administrative order, not the preliminary report, which is the basis of any further remedies the losing party in an administrative case may pursue.[24] | |||||
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2006-11-24 |
YNARES-SANTIAGO, J. |
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| Finally, the Ombudsman and the Court of Appeals correctly held that there is substantial evidence proving petitioner's liability under R.A. No. 6713. Substantial evidence is such relevant evidence as a reasonable mind may accept as adequate to support a conclusion.[32] The requirement is satisfied where there is reasonable ground to believe that the petitioner is guilty of misconduct, even if the evidence might not be overwhelming.[33] | |||||
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2005-09-30 |
TINGA, J. |
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| A finding of guilt in an administrative case would 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.[49] Substantial evidence has been defined as such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. This is different from the degree of proof required in criminal proceedings, which calls for a finding of guilt beyond reasonable doubt.[50] Petitioner's reliance on the rules on prosecution for the crime of rape is therefore misplaced. What is at issue in the case before the Ombudsman is whether his acts constitute grave misconduct, and not whether he is guilty of the crime of attempted rape. | |||||