Quantum of proof required in administrative, civil and criminal cases
A small compilation of pertinent laws and court decisions
by Jose Rizal M. Reyes
The 2019 local election in Romblon is full of talks about cases — cases that have been filed, cases that are being filed and cases that will be filed. There is every indication that this controversy will go on far beyond the election period.
As charges of corruption as well as libelous statements go back and forth between some keyboard warriors and between some candidates themselves, both camps oftentimes challenge each other to file a case in court.
In view of this, we decided to prepare this little compilation of existing Philippine laws on the subject to serve as a brief introduction on the proof or evidence that would be needed in order to successfully seek out punishment for wrongdoing.
A curious thought crossed my mind regarding politically-connected cases both camps have to grapple with today and tomorrow. Will they strike a deal somewhere down the road or will they slug it out in court till the bitter end?
Differences Among Criminal, Civil and Administrative Cases
- Criminal law deals with crimes and their prosecution. A case involving violation of criminal law is a criminal case. A criminal case involves an action that is considered to be harmful to society as a whole (hence, it is considered an offense against the State and the case is docketed as People of the Philippines vs. So-and-So).
- Civil law is the law governing the relations between private persons or organizations. A case involving violation of civil law is likewise a civil case. A civil case involves two or more parties. It is a kind of a lawsuit that usually deals with contracts and torts (wrongful or negligent acts that result in damage or injury).
- Administrative law is the law regarding the rules or regulations made and enforced by governmental agencies. A case involving violation of administrative law is thus an administrative case. This is a case between state authority on the one side and a person from the other.
Hierarchy of Evidentiary Values
- Proof beyond reasonable doubt
(hardest to prove, required in Criminal Case) - Clear and convincing proof
- Preponderance of Evidence
(second easiest to prove, required in Civil Case) - Substantial evidence
(easiest to prove, required in Administrative Case)
>> In the hierarchy of evidentiary values, proof beyond reasonable doubt is at the highest level, followed by clear and convincing evidence, preponderance of evidence and substantial evidence, in that order. <<
( http://www.mvplaw17.com/node/175)
>> Clear and convincing proof is “. . . more than mere preponderance, but not to extent of such certainty as is required beyond reasonable doubt as in criminal cases . . .” while substantial evidence “. . . consists of more than a mere scintilla of evidence but may be somewhat less than a preponderance . . . .” Consequently, in the hierarchy of evidentiary values, We find proof beyond reasonable doubt at the highest level, followed by clear and convincing evidence, preponderance of evidence, and substantial evidence, in that order. <<
( G.R. №102358 / November 19, 1992)
ADMINISTRATIVE CASE REQUIRES ONLY SUBSTANTIAL EVIDENCE
>> Substantial evidence is defined as such amount of relevant evidence which a reasonable mind might accept as adequate to support a conclusion. It is more than a mere scintilla of evidence. The standard of substantial evidence is satisfied when there is reasonable ground to believe, based on the evidence submitted, that the respondent is responsible for the misconduct complained of. It need not be overwhelming or preponderant, as is required in an ordinary civil case, or evidence beyond reasonable doubt, as is required in criminal cases, but the evidence must be enough for a reasonable mind to support a conclusion. <<
(G.R. Nos. 172532 172544–45 / November 20, 2013)
>> In the hierarchy of evidentiary values, substantial evidence, or that amount of relevant evidence which a reasonable man might accept as adequate to justify a conclusion, is the lowest standard of proof provided under the Rules of Court. <<
(AM No. P-11–3019 — Supreme Court of the Philippines / March 2012)
CIVIL CASE REQUIRES PREPONDERANCE OF EVIDENCE
>> Section 1, Rule 133 of the Rules of Court mandates that in civil cases, the party having the burden of proof must establish his case by a preponderance of evidence. By preponderance of evidence, according to Raymundo v. Lunaria, [means] that the evidence as a whole adduced by one side is superior to that of the other. It refers to the weight, credit and value of the aggregate evidence on either side and is usually considered to be synonymous with the term “greater weight of evidence” or “greater weight of the credible evidence.” It is evidence which is more convincing to the court as worthy of belief than that which is offered in opposition thereto. <<
(G.R. №214406 / February 6, 2017)
CRIMINAL CASE REQUIRES PROOF BEYOND REASONABLE DOUBT
>> Well-entrenched in jurisprudence is the rule that the conviction of the accused must rest, not on the weakness of the defense, but on the strength of the prosecution. The burden is on the prosecution to prove guilt beyond reasonable doubt, not on the accused to prove his innocence. <<
(G.R. №175842 / March 18, 2015)
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