Monday, February 27, 2012

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, October 18, 2007; Section 5, Rule 133 of the Rules of Court).

Anent the issue of falsification of public documents, there is substantial evidence to hold the respondent guilty of dishonesty for falsifying an official document.

EN BANC

A.M. No. P-10-2833* December 14, 2010

RETIRED EMPLOYEE, Municipal Trial Court, Sibonga, Cebu, Complainant,
vs.
MERLYN G. MANUBAG, Clerk of Court II, Municipal Trial Court, Sibonga, Cebu, Respondent.

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