January 26, 2012
"As an administrative proceeding, the evidentiary bar against which the evidence at hand is measured is not the highest quantum of proof beyond reasonable doubt, requiring moral certainty to support affirmative findings. Instead, the lowest standard of substantial evidence, that is, such relevant evidence as a reasonable mind will accept as adequate to support a conclusion, applies. Because administrative liability attaches so long as there is some evidence adequate to support the conclusion that acts constitutive of the administrative offense have been performed (or have not been performed), reasonable doubt does not ipso facto result in exoneration unlike in criminal proceedings where guilt must be proven beyond reasonable doubt. This hornbook doctrinal distinction undergirds our parallel findings of administrative liability and criminal acquittal on reasonable doubt for charges arising from the same facts."

Miro v. Dosono, G.R. No. 170697, April 30, 2010

January 25, 2012
"

Public office is a public trust. A public servant must bear at all times the highest sense of honesty. This is especially significant for employees in the judiciary. The image of a court of justice is necessarily mirrored in the conduct, official or otherwise, of its personnel, from the judge to the lowest employee. Hence, those involved in the administration of justice must live up to the highest standard of honesty and integrity in the public service. Not only must their conduct at all times be characterized by propriety and decorum but, above all else, it must be beyond suspicion…

In administrative proceedings, the quantum of proof necessary for a finding of guilt is substantial evidence or such relevant evidence as a reasonable mind may accept as adequate to support a conclusion. Well-entrenched is the rule that substantial proof, and not clear and convincing evidence or proof beyond reasonable doubt, is sufficient as basis for the imposition of any disciplinary action upon the employee. The standard of substantial evidence is satisfied where the employer, as in this case the Court, has reasonable ground to believe that the employee is responsible for the misconduct and his participation therein renders him unworthy of trust and confidence demanded by his position.

"

Filoteo v. Calago, A.M. No. P-04-1815 (Formerly OCA IPI No. 04-1885-P), October 18, 2007