The issue of what standard of evidence will be used in determining the fate of Chief Justice Renato Corona has cropped up in the impeachment trial at the Senate. The prosecution is of the opinion that the standard should be “substantial evidence”, while the defense claims that it should be “proof beyond reasonable doubt”. It is now worth examining the different standards of evidence under the Rules of Court and related jurisprudence.
Substantial evidence is more than a mere scintilla of evidence. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion, even if other minds equally reasonable might conceivably opine otherwise. [Montemayor v. Bundalian, 453 Phil. 158, 167 (2003).]
In administrative proceedings, the quantum of proof necessary for a finding of guilt is substantial evidence, i.e., that amount of relevant evidence that a reasonable mind might accept as adequate to support a conclusion. Further, the complainant has the burden of proving by substantial evidence the allegations in his complaint. The basic rule is that mere allegation is not evidence and is not equivalent to proof. Charges based on mere suspicion and speculation likewise cannot be given credence. Hence, when the complainant relies on mere conjectures and suppositions, and fails to substantiate his allegations, the administrative complaint must be dismissed for lack of merit.
PROOF BEYOND REASONABLE DOUBT
Proof beyond reasonable doubt means proof to the satisfaction of the court and keeping in mind the presumption of innocence that precludes every reasonable hypothesis except that for which it is given. It is not sufficient for the proof to establish a probability, even though strong, that the fact charged is more likely true than the contrary. It must establish the truth of the fact to a reasonable certainty and moral certainty – a certainty that convinces and satisfies the reason and conscience of those who are to act upon it. [People v. Castillo, G.R. No. 132895, March 10, 2004, 425 SCRA 136, 166, citing United States v. Reyes, 3 Phil. 6 (1903).]
The Constitution itself provides that in all criminal prosecutions, the accused shall be presumed innocent until the contrary is proved. An accused is entitled to an acquittal unless his guilt is shown beyond reasonable doubt. It is the primordial duty of the prosecution to present its side with clarity and persuasion, so that conviction becomes the only logical and inevitable conclusion, with moral certainty.
The necessity for proof beyond reasonable doubt was discussed in People v. Berroya [347 Phil. 410, 423 (1997)]:
[Proof beyond reasonable doubt] lies in the fact that in a criminal prosecution, the State is arrayed against the subject; it enters the contest with a prior inculpatory finding in its hands; with unlimited means of command; with counsel usually of authority and capacity, who are regarded as public officers, as therefore as speaking semi-judicially, and with an attitude of tranquil majesty often in striking contrast to that of defendant engaged in a perturbed and distracting struggle for liberty if not for life. These inequalities of position, the law strives to meet by the rule that there is to be no conviction where there is reasonable doubt of guilt. However, proof beyond reasonable doubt requires only moral certainty or that degree of proof which produces conviction in an unprejudiced mind.
PREPONDERANCE OF EVIDENCE
Preponderance of evidence” is the weight, credit, and value of the aggregate evidence on either side and is usually considered synonymous with the term “greater weight of the evidence” or “greater weight of the credible evidence.” “Preponderance of evidence” is a phrase that, in the last analysis, means probability of the truth. It is evidence that is more convincing to the court as worthy of belief than that which is offered in opposition thereto. [Perfecta Cavile, Jose de la Cruz and Rural Bank of Bayawan, Inc. v. Justina Litania-Hong, accompanied and joined by her husband, Leopoldo Hong and Genoveva Litania, G.R. No. 179540, March 13, 2009, citing Go v. Court of Appeals, 403 Phil. 883, 890-891 (2001).]
Rule 133, Section 1 of the Rules of Court provides the guidelines in determining preponderance of evidence, thus:
SECTION I. Preponderance of evidence, how determined. In civil cases, the party having burden of proof must establish his case by a preponderance of evidence. In determining where the preponderance or superior weight of evidence on the issues involved lies, the court may consider all the facts and circumstances of the case, the witnesses’ manner of testifying, their intelligence, their means and opportunity of knowing the facts to which they are testifying, the nature of the facts to which they testify, the probability or improbability of their testimony, their interest or want of interest, and also their personal credibility so far as the same may legitimately appear upon the trial. The court may also consider the number of witnesses, though the preponderance is not necessarily with the greater number.