Substantial Evidence

 The quantum of evidence required in cases filed before administrative and quasi-judicial
bodies is substantial evidence.
 The pertinent rule on substantial evidence is found in Sec. 5 of Rule 133. The relevant
provision declares: "Sec. 5. Substantial evidence. — In cases filed before administrative
or quasi-judicial bodies, a fact may be deemed established if it is supported by
substantial evidence, or that amount of relevant evidence which a reasonable mind
might accept as adequate to justify a conclusion."
 In administrative cases, substantial evidence is required to support any
finding. Substantial evidence is such relevant evidence as a reasonable mind
may accept as adequate to support a conclusion. The requirement is satisfied
where there is reasonable ground to believe that the petitioner is guilty of the
act or omission complained of, even if the evidence might not be
overwhelming. While in criminal cases, the accused is entitled to an
acquittal, unless his guilt is shown beyond a reasonable doubt.

6. In one case, while recognizing the rule that in administrative proceedings, complainants have
the burden of proving the allegations in their complaints by substantial evidence, the Supreme
Court held that administrative proceedings against judges are highly penal in character and are
to be governed by the rules applicable to criminal cases. The quantum of proof required to
support administrative charges against judges should thus be more than substantial and requires
proof beyond reasonable doubt (Duduaco v. Laquin- danum, 466 SCRA 428). Surprisingly, this
quantum of proof was later extended to an administrative case filed against a sheriff for
harassment and misconduct where the court held that administrative proceedings against
judicial employees, are by nature, highly penal in character and are to be governed by the rules
governing criminal cases. Accordingly, the quantum of evidence required to support the
administrative charges should thus be more than substantial and they must be proven beyond
reasonable doubt (Arnado v. Suarin, A.M. No. P-05-2059, 467 SCRA 402, citing Duduaco v.
Laquinda- num, 466 SCRA 428).

Effect of Failure to Prove Administrative Liability on the Criminal Case

In Paredes v. Court of Appeals (G.R. No. 169534, July 30, 2007), the accused argued that as his
liability in the administrative case against him was not established by substantial evidence, so will
his criminal case necessarily fall, demanding as it does, a heavier quantum of proof, i.e., proof
beyond reasonable doubt. To this argument the Supreme Court declared:

"...Criminal and administrative proceedings may involve similar operative facts; but each requires
a different quantum of evidence. 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.
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.

"The petition must fail.

".. It is indeed a fundamental principle ... that administrative cases are independent from criminal
actions for the same act or omission. Thus, an absolution from a administrative charge is not a
bar to an criminal prosecution, or vice versa. One thing is administrative liability; quite another
thing is the criminal liability for the same act.