1. Sacdalan vs.

CA
G.R. no. 128967 May 20, 2004
The DAR Provincial Adjudicator and the DARAB should have been more
circumspect in the disposition of this case. Instead of facilitating the
administration of justice, their obstinate refusal to obey a valid final
judgment of the Court of Appeals, further delayed the resolution of this case
and added valuable irretrievable years to a case that has already dragged on
for decades.
2. Qulato vs. Vios
A.M. no. MTJ-04-1551, May 21, 2004
As a matter of policy, in the absence of fraud, dishonesty or corruption,
the acts of a judge in his judicial capacity are not subject to disciplinary
action even though such acts are erroneous.
However, erroneously a judges belief that counsel for the accused has
no right to waive the presentation of evidence, the same may only be
considered an error judgment- a judges failure to interpret the law or to
property appreciate the evidence presented does not necessarily render him
administratively liable.
An administrative complaint against a judge cannot be pursued
simultaneously with the judicial remedies accorded to parties aggrieved by
his erroneous order or judgment.
Respondent judges actuations of virtually compelling a lawyer to
withdraw as counsel for the accused, threatening to punish him for contempt
of court if he would refuse, amount to vulgar and unbecoming conduct,
classified as a light charge under Rule 140 of the Rules of Court, as amended
by A. M. No. 01-8-10-SC.
3. Pasong Bayabas Farmers Association, Inc. v. Court of Appeals
Agricultural lands are only those lands which are arable or suitable
lands that do not include commercial, industrial and residential lands.

4. Bon v. Ziga
A.C. No. 5436. May 27, 2004
Notarization is not an empty, meaningless, routinary act.

Notaries Public must observe with utmost care the basic requirements
in the performance for their duties.
5. De Juan v. Baria III
A.C. No. 5817, May 27, 2004

Among the fundamental rules of ethics is the principle that an attorney who
undertakes an action impliedly stipulates to carry it to its termination, that is,
until the case becomes final and executory.
A lawyer is not at liberty to abandon his client and withdraw his services
without reasonable cause and only upon notice appropriate in the
circumstances.
Negligence of lawyer in connection with legal matters entrusted to them for
handling shall render them liable.
An attorney may only retire from the case either by a written consent of his
client or by permission of the court after due notice and hearing, in which
event the attorney should see to it that the name of the new attorney is
recorded in the case.
6. Ricafort vs. bansil
Adm. Case No. 6298

May 27, 2004

As a matter of procedure, the Investigating Commissioner should have

proceeded with the investigation ex parte pursuant to the provisions of
Section 8, Rule 139-B of the Rules of Court.
Where the complaint a lawyer is in connection with the discharge of his
functions as a notary public, and not as an elected barangay chairman.
Thus, the Code of Conduct and Ethical Standards for Public Officials
and Employees invoked by complainant will not apply to the present
administrative complaint against respondent. Respondent, as a lawyer
and a notary public, is covered by the Code of Professional
Responsibility and Code of Professional Ethics.
7. Re: Withholding of All the Salaries and Allowances of Mr. Datu Ashary
M. Alauya, Clerk of Court, 4th Sharia District Court, Marawi City
A.M. No. SDC-03-4-P. May 27, 2004

A clerk of court and the administrative functions he performs are vital

to the prompt and proper administration of justice.
As court custodian, a clerk of court has the responsibility to ensure that
records are safely kept and the same are readily available upon the
request of the parties or order of the court.
As custodian of judicial records, it is incumbent upon him to ensure an
orderly and efficient record management system in the court and to
supervise the personnel under his office to function effectively.

8. Bejarasco, Jr. vs. Buenconsejo

A.M. No. MTJ-02-1417. May 27, 2004
A judgment, to be valid, must have been personally and directly
prepared by the judge, and duly signed by him.
Judgment may be promulgated by the clerk of court only when the
judge is absent or outside the province or city.
Decisions promulgated after the judge who penned the same had been
appointed to and qualified in another office are null and void; In single
courts like the regional trial courts and the municipal trial courts, a
decision may no longer be promulgated after the ponente has vacated
his office.
Administrative cases may proceed independently of criminal
proceedings, and may continue despite the dismissal of the latter
charges.
9. Obaana Jr vs Ricafort
A.M. No. MTJ-04-1545. May 27, 2004
A clerk of court occupies a very sensitive position that requires
competence and efficiency to insure the publics confidence in the
administration of justice- he cannot be permitted to slacken on his job
under one pretext or another.
A clerk of court is also responsible in ensuring the orderly and efficient
record management system in the court and to supervise the
personnel under his office to function effectively.

10.
Aquino, Jr. vs. Miranda
A.M. No. P-01-1453. May 27, 2004
A public servant whose career is on the line would normally want the
investigating body to know his or her whereabouts for purposes of
notice.
The Court is not ousted of its jurisdiction over an administrative case
by the mere fact that the respondent public official ceases to hold
office during the pendency of respondents case.
The men and women who work in the judiciary must always act with
propriety for the image of a court of justice is mirrored in the conduct
of its personnel.
The conduct of all those involved in the administration of justice from
the judge to the lowliest clerk is circumscribed with the heavy burden
of responsibility, accountability, integrity, uprightness and honesty.
To constitute grave misconduct, the acts complained of should be
corrupt or inspired by an intention to violate the law, or constitute
flagrant disregard of well-known legal rules.

11.
Sismaet vs. Sabas
A.M. No. P-03-1680. May 27, 2004
Sheriffs play an important role in the administration of justice because
they are tasked to execute the final orders and judgments of the
courts; The sheriff charged with this task must act with considerable
dispatch so as not to delay the administration of justice.
The duty of a sheriff to execute a valid writ is ministerial and not
discretionary. A purely ministerial act or duty is one which an officer or
tribunal performs in the context of a given set of facts, in a prescribed
manner and without regard to the exercise of his own judgment upon
the propriety or impropriety of the act done. A discretionary act, on the
other hand, is a faculty conferred upon a court or official by which he
may decide the question either way and still be right.

The conduct of every person connected with an office charged with the
dispensation of justice, from the presiding judge to the lowest clerk, is
charged with a heavy burden of responsibility.

12.
Dy vs. Pascua
A.M. No. P-04-1798. May 27, 2004
The Supreme Courts authority cannot be dependent on or frustrated
by private arrangement between parties.
Judges are authorized to discipline erring court personnel in their
respective salas, but such authority must not be exercised arbitrarily.
Where the employees act of discourtesy is their first offense, the
disciplining judge has no authority to suspend them outright-they
should only have been reprimanded for their unruly behavior.
Court personnel must, at all times, act with strict propriety and proper
decorum so as to earn the publics regard for the judiciary.

13.
Sison vs. Caoibes, Jr.
A.M. No. RTJ-03-1771. May 27, 2004
A judge should never allow himself to be moved by pride, prejudice,
passion or pattiness in the performance of his duties.
While at first blush, it would seem that the respondent judge was
justified in holding the complainant for contempt, due to the latters
refusal to comply with the judges order, it is not lost upon this Court
that the complainant was not a party to any of the cases pending
before the respondent judge.
The
fact
that
the
respondent
judge
insisted
that
the
complainant personally file his comment in court gives rise to doubts
as to the motive behind it; as the Investigating Justice puts it, the
requirement of personal filing was deliberately inserted so that the
respondent could confront and harass the complainant.
The act of a judge in citing a person in contempt of court in a manner
which smacks of retaliation, as in the case at bar, is appalling and

violative of Rule 2.01 of the Code of Judicial Conduct which mandates

that a judge should so behave at all times to promote public
confidence in the integrity and impartiality of the judiciary.
The Court has not been blind to the improper use by judges of the
erstwhile inherent power of contempt which, in fine, amounts to grave
abuse of authority.
14.
Floresta vs. Ubiadas
A.M. No. RTJ-03-1774. May 27, 2004
The proper recourse of a party aggrieved by the decision of a judge is
to appeal to the proper court, not file an administrative complaint.
Only in cases where the error is gross or patent, deliberate and
malicious, or incurred with evident bad faith may administrative
sanctions be imposed.
Article VIII, Section 15(1) of the 1987 Constitution and Canon 3, Rule
3.05 of the Code of Judicial Conduct direct judges to dispose of their
cases promptly and within the prescribed periods, failing which they
are liable for gross inefficiency.

15.
Bernardo vs. Court of Appeals
G.R. No. 124261
May 27, 2004
The Civil Service Commission erred in finding an employee
administratively liable for acts not alleged in the formal charges- the
employee was deprived of his right to be informed of the charges
against him, and to accord him the right to adduce evidence to
controvert the said charges.
The Supreme Court has categorically pronounced that "the nature and
responsibilities of public officers enshrined in the 1987 Constitution
and oft-repeated in our case law are not mere rhetorical words, not to
be taken as idealistic sentiments but as working standards and
attainable goals that should be matched with actual deeds."

The causes which warrant the dismissal of a civil servant need not
necessarily be work-related or committed in the course of the
performance of duty by the person charged.
Administrative decisions on matters within their jurisdiction are entitled
to respect and can only be set aside on proof of grave abuse of
discretion, fraud or error of law.

16.
Apuyan, Jr. vs. Sta. Isabel
A.M. NO. P-01-1497 : May 28, 2004
Section 53 of the Revised Uniform Rules on Administrative Cases in the
Civil Service which provides that in the determination of the penalties
to be imposed, the extenuating, mitigating, aggravating or alternative
circumstances may be considered.
17.
Fernandez, Jr. vs. Gatan
A.M. No. P-03-1720. May 28, 2004
Grave misconduct is a malevolent transgression of some established
and definite rule of action, more particularly, unlawful behavior or
gross negligence by the public officer or employee which threatens the
very existence of the system of administration of justice.

18.
Reliways, Inc. vs. Grantoza
A.M. NO. P-04-1812 : May 28, 2004
Willful failure to pay just debts classified as a light offense and
reprimand is the penalty for the first offense.

19.
Portic vs. Villalon- Pornillos
A.M. No. RTJ-02-1717. May 28, 2004
Administrative charges against members of the judiciary must be
supported at least by substantial evidence.
An inquiry into the administrative liability of a judge may be resorted to
only after the available remedies have been exhausted and decided
with finality.

20.
San Juan de Dios Educational Foundation Employees UnionAlliance of Filipino Workers vs. San Juan de Dios Educational
Foundation, Inc.
G.R. No. 143341. May 28, 2004
The findings of fact of quasi-judicial bodies like the NLRC, are accorded
with
respect,
even
finality,
if
supported
by
substantial
evidence. Particularly when passed upon and upheld by the Court of
Appeals, they are binding and conclusive upon the Supreme Court and
will not normally be disturbed.

21.
Re: Administrative Liabilities of the Security Personnel Involved in
the Entry of an Unidentified person at the Philippine Judicial Academy
A. M. No. 2003-18-SC. June 3, 2004
The conduct and behavior of everyone connected with an office
charged with the dispensation of justice, from the presiding judge to
the lowliest clerk, should be circumscribed with the heavy burden of
responsibility.
Simple neglect of duty, classified as a less grave offense, carries a
penalty of suspension for one month and one day to six months for the
first violation.

22.
Re: AC No. 04-AM-2002 (Josefina Fria vs. Gemiliana De Los
Angeles
A.M. No. CA-02-15-P. June 3, 2004
In administrative proceedings, the complainant has the burden of
proving, by substantial evidence, the allegations in the complaint.
Complainant failed to discharge the quantum of evidence substantial
evidence to fault respondent.
23.
Office of the Court of Administrator vs. Villegas
A.M. No. RTJ-00-1526. June 3, 2004
The noble office of a judge is to render justice not only impartially but
expeditiously as well, for delay in the disposition of cases erodes the

faith and confidence of our people in the judiciary, lowers its standards
and brings it into disrepute.
Judge Villegas contumacious conduct and blatant disregard of the
Courts mandate for more than three years amounted to studied
defiance and downright insubordination.

24.
Civil Service Commission vs. Cortez
G. R. No. 155732. June 3, 2004
Under the Civil Service Law and its implementing rules, dishonesty,
grave misconduct and conduct grossly prejudicial to the best interest
of the service are grave offenses punishable by dismissal from the
service.

25.
Duenas vs. Santos Subdivision Owners Association
G.R. No. 149417. June 4, 2004
While the Court has held that before a party is allowed to seek
intervention of the courts, it is a pre condition that he avail himself of
all administrative processes afforded him, nonetheless, said rule is not
without exceptions.

26.
Re: Habitual tardiness Incurred by Mr. Gideon M. Alibang for the
First Semester of 2003
A.M. No. 2003-11-S C. June 15, 2004
An employee shall be considered habitually tardy if he incurs tardiness,
regardless of the number of minutes, ten (10) times a month for at
least two (2) months in a semester or at least two (2) consecutive
months during the year.
Moral obligations, performance of household chores and traffic
problems are not sufficient reasons to excuse habitual tardiness,
although in certain cases these may be considered to mitigate
administrative liability.

By reason of the nature and functions of their office, officials and

employees of the Judiciary must be role models in the faithful
observance of the constitutional cannon that public office is a public
trust. Inherent in this mandate are the observance of prescribed office
hours and the efficient use of every moment thereof for public service.

27.
Freedom from Debt Coalition vs. Energy Regulatory Commission
G.R. No. 161113
June 15, 2004
The rules require that a certification of the notice of publication should
accompany the application.
It is not required to wait until all pleadings are submitted nor is its
power to issue provisional orders stayed by pending matters such as
motions for production of documents.
It is therefore purposeless for the majority to annul the questioned
order and require the republication of MERALCOs application.
An administrative agency may be empowered to approve provisionally,
when demanded by urgent public need, rates of public utilities without
hearing.
The authority to issue provisional orders of rate adjustments cannot be
considered as one of the powers that the legislature intended the ERC
to possess, for if it were intention of the lawmakers, there would not
have been a black hole in the law.
The power to fix prices and make rates cannot be conferred by
implication, but must be conferred under statutory or constitutional
language that is free from doubt, and admits of no other reasonable
construction.
Considering the EPIRA does not contain the authority to grant
provisional rates, it follows then that to insist that the ERC has such
authority, would be to grant the ERC an authority that would be
inconsistent with the EPIRA.
The publication made by MERALCO, obviously, does not sufficiently
inform the public of the nature and substance of the application, as
intended by law.

28.
Professional Regulation Commission vs. De Guzman
G.R. No. 144681. June 21, 2004
The power to regulate the exercise of a profession or pursuit of an
occupation cannot be exercised by the State or its agents in an
arbitrary, despotic, or oppressive manner.
The doctrine of exhaustion of administrative remedies does not apply
where, as in this case, a pure question of law is raised.

29.
Velasco vs. Court of Appeals
G.R. No. 130244. July 7, 2004

The meaning of duplicate original copy, thus: 1. The duplicate original

copy shall be understood to be that copy of the decision, judgment,
resolution or order which is intended for and furnished to a party in the case
or proceeding in the court or adjudicative body which rendered and issued
the same. . . .2. The duplicate original copy must be duly signed or initialed
by the authorities or the corresponding officer or representative of the
issuing entity, or shall at least bear the dry seal thereof or any other official
indication of the authenticity and completeness of such copy. . . .

Pursuant to paragraph 2 of the Supreme Court Administrative Circular No. 396, the presence of the seal qualifies the document as a duplicate original
copy

30.

Dwikarna vs. Domingo

G.R. No. 153454. July 7, 2004

Courts will not interfere in matters which are addressed to the sound
discretion of government agencies entrusted with the regulation of

activities coming under the special technical knowledge and training of

such agencies.

A person convicted of a crime and ordered deported at the same time

must first serve his sentence before he is deported.

31.
Querubin vs. Regional Cluster Director, Legal and Adjudication
Office, COA Regional Office No. VI, Pavia, Iloilo City
G.R. No. 159299, July 7, 2004
Section 13 of PD 198, as amended, categorically forbids the grant of
bonuses and allowances other than payment of per diems.
32.
Cambaliza vs. Cristal-Tenorio
Adm. Case No. 6290, July 14, 2004
A case of suspension or disbarment may proceed regardless of interest
or lack of interest of the complainant.
When the criminal prosecution based on the same act charged is still
pending in court, any administrative disciplinary proceedings for the
same act must await the outcome of the criminal case to avoid
contradictory findings.
A lawyer who allows a non-member of the Bar to misrepresent himself
as a lawyer and to practice law is guilty of violating Canon 9 and Rule
9.01 of the Code of Professional Responsibility.
33.
Mupas vs. Espanol
A.M. No. RTJ-04-1850. July 14, 2004
It is elementary that an Executive Judge only has administrative
supervision over lower courts. Her function relates only to the
management of first and second level courts, within her administrative
area with a view to attaining prompt and convenient dispatch of its
business. Acting as such, she cannot unilaterally override the MTCs
actions in cases pending with it under the guise of administrative

supervision, without running afoul of the orderly administration of

justice. Only when her courts jurisdiction is appropriately invoked in
an appeal or certiorari and other special civil actions can respondent
judge, in her judicial capacity, override the lower courts judgment.
The powers of an executive judge relate only to those necessary or
incidental to the performance of his/her functions in relation to court
administration.
The earnest efforts of judges to promote a speedy administration of
justice must at all times be exercised with due recognition of the
boundaries and limits of their jurisdiction or authority. Respondent's
ardent determination to expedite the case and render prompt justice
may be a noble objective but she did so in a manner which took away
from the complainant MTC judge the initiative which by constitutional
and legal mandates properly belongs to her.
With regard to the hold-departure order, Circular No. 39-97 limits the
authority to issue hold-departure orders to criminal cases within the
jurisdiction of second level courts

34.
Rivera vs. Mirasol
A.M. No. RTJ-04-1885. July 14, 2004
In the absence of fraud, dishonesty or corruption, the acts of a judge in
his official capacity do not always constitute misconduct although the
same acts may be erroneous. True, a judge may not be disciplined for
error of judgment absent proof that such error was made with a
conscious and deliberate intent to cause an injustice. This does not
mean, however, that a judge need not observe propriety, discreetness
and due care in the performance of his official functions.
Cessation from office because of retirement does not warrant the
dismissal of the administrative complaint filed against him while he
was still in service.

35.
Eastern telecommunications Philippines, Inc. vs. International
communication Corporation
G.R. No. 135992. July 23, 2004

The National telecommunications Commission as the regulatory

agency of the national government with jurisdiction over all
telecommunications entities, it is clothed with authority and given
ample discretion to grant a provisional permit or authority. [11]It also has
the authority to issue Certificates of Public Convenience and Necessity
(CPCN) for the installation, operation, and maintenance of
communications facilities and services, radio communications systems,
telephone and telegraph systems, including the authority to determine
the areas of operations of applicants for telecommunications services.

36.
Globe Telecom, Inc.
Commission
G.R. No. 143964. July 26, 2004

vs.

National

Telecommunications

Every party subject to administrative regulation deserves an

opportunity to know, through reasonable regulations promulgated by
the agency, of the objective standards that have to be met. Such rule
is integral to due process, as it protects substantive rights.
It is not relevant to this case that the process for obtaining prior
approval under the PTA and its Implementing Rules is administrative in
nature. While this may be so, the assailed NTCs determination and
corresponding penalty were rendered in the exercise of quasi-judicial
functions- all the requirement of due process attendant to the exercise
of quasi-judicial power apply.
The Court usually accords great respect to the technical findings of
administrative agencies in the fields of their expertise, even if they are
infelicitously worded. However, the above-quoted finding is nothing
more than bare assertions, unsupported by substantial evidence.
Judicial fact-finding of the de novo kind is generally abhorred and the
shift of decisional responsibility to the judiciary is not favored as
against the substantiated and specialized determination of
administrative agencies.
While stability in the law, particularly in the business field, is desirable,
there is no demand that the NTC slavishly follow precedent. [82]However,
we think it essential, for the sake of clarity and intellectual honesty,

that if an administrative agency decides inconsistently with previous

action, that it explain thoroughly why a different result is warranted, or
if need be, why the previous standards should no longer apply or
should be overturned.
It is clear that before NTC could penalize Globe and Smart for
unauthorized provision of SMS, it must first establish that SMS is VAS.
The opportunity to adduce evidence is essential in the administrative
process, as decisions must be rendered on the evidence presented,
either in the hearing, or at least contained in the record and disclosed
to the parties affected.
Notice and hearing are the bulwark of administrative due process, the
right to which is among the primary rights that must be respected
even in administrative proceedings.
It is essential to emphasize the need for a hearing before a fine may be
imposed, as it is clearly a punitive measure undertaken by an
administrative agency in the exercise of its quasi-judicial functions.
Inherently, notice and hearing are indispensable for the valid exercise
by an administrative agency of its quasi-judicial functions.
The credibility of an administrative agency entrusted with specialized
fields subsists not on judicial doctrine alone, but more so on its
intellectual strength, adherence to law, and basic fairness.

37.
Almojuela, Jr. vs. Ringor
A.M. No. MTJ-04-1521. July 27, 2004
Every judge is required to observe the law. When the law is sufficiently
basic, a judge owes it to his office to simply apply it; and anything less
than that would be constitutive of gross ignorance of the law. In short,
when the law is so elementary, not to be aware of it constitutes gross
ignorance of the law.
A judge should be studious of the principles of law.
It is highly imperative that judges be conversant with the law and
basic legal principles.

The misconduct must imply wrongful intention and not a mere error of
judgment.
38.
Philippine Ports Authority
Development Corp.
G.R. No. 146478. July 30, 2004

vs.

Sargasso

Construction

&

By force Administrative Code, the GOCC is the lead counsel of all

GOCCs and no agreement or arrangement entered into by, or any act
of omission of, GOCC can alter set-up.

39.
Fernandez vs. Verzola
A.M. No. CA-04-40. August 13, 2004
In administrative proceedings, the complainant has the burden of
proving by substantial evidence the allegations in his complaint. In the
absence of evidence to the contrary, the presumption that the
respondent has regularly performed his duties will prevail. Even in
administrative cases, if a respondent judge should be disciplined for a
grave offense, the evidence against him should be competent and
derived from direct knowledge.
Court will not shirk from its responsibility of imposing discipline upon
its employees, judges and Associate Justices alike; but neither will it
hesitate to shield them from unfounded suits that serve to disrupt
rather than promote the orderly administration of justice.

40.
Re: Report on Financial Audit Conducted in the RTC, Br. 34,
Balaoan, La Union
A.M. No. 02-1-66-RTC. August 19, 2004
Clerks of court are presumed to be aware of their duty to immediately
deposit the various funds received by them in the authorized
government depositories for they are not supposed to keep funds in
their personal possession.
The Court condemns any conduct, act or omission which violates the
norm of public accountability or diminishes the faith of the people in
the judiciary.

41.
Office of the Court Administrator vs. Fernandez
A.M. No. MTJ-03-1511. August 20, 2004
The retirement of a judge or any judicial officer from the service does
not preclude the finding of any administrative liability to which he shall
still be answerable.
Respondent judge is guilty of simple misconduct for violating the rules
on bail.

42.
Habitual Tardiness of Arthur R. Cabigon, Sheriff IV, RTC-OCC,
Cebu City
A.M. No. 04-5-277-RTC. August 31, 2004
By reason of the nature and functions of their office, officials and
employees of the Judiciary must be role models in the faithful
observance of the constitutional canon that public office is a public
trust.
Moral obligations and mundane considerations such as performance of
household chores, traffic problems and health, domestic and financial
concerns are not sufficient reasons to excuse habitual tardiness,
although these may be considered to mitigate administrative liability.

43.
Re: Habitual tardiness of Guendolyn C. Sison, Clerk III, Regional
Trial Court, Br. 23, Cebu City
A.M. No. P-04-1860. August 31, 2004
Moral obligations, performance of household chores, traffic problems
and health, domestic and financial concerns are not sufficient reasons
to excuse habitual tardiness.
By reason of the nature and functions of their office, the officials and
employees of the Judiciary must be role models in the faithful
observance of the constitutional canon that public office is a public
trust.

44.
Re: Habitual Tardiness of Mario J. Tamang, Sheriff IV, RTC, Br. 168,
Pasig City
A.M. No. P-04-1861. August 31, 2004
Moral obligations, performance of household chores, traffic problems
and health, domestic and financial concerns are not sufficient reasons
to excuse habitual tardiness.
By reason of the nature and functions of their office, the officials and
employees of the Judiciary must be role models in the faithful
observance of the constitutional canon that public office is a public
trust.
45.
Concerned Citizen vs. Bautista
A.M. NO. P-04-1876 : August 31, 2004
The avowed objective of Administrative Circular No. 5 dated October 4,
1988 is to ensure that the entire time of the officials and employees in
the Judiciary be devoted to their official work to insure the efficient and
speedy administration of justice.
46.
Velasquez vs. Hernandez
G.R. No. 150732. August 31, 2004
One may be heard, not solely by verbal presentation but also, and
perhaps even many times more creditably than oral argument, through
pleadings.
Technical rules of procedure and evidence are not even strictly applied
to administrative proceedings, and administrative due process cannot
be fully equated to due process in its strict judicial sense.
A finding of guilt in an administrative case would have to be sustained
for as long as it is supported by substantial evidence that the
respondent has committed the acts stated in the complaint or formal
charge. As defined, substantial evidence is such relevant evidence as
a reasonable mind may accept as adequate to support a conclusion.
This is different from the quantum of proof required in criminal
proceedings which necessitates a finding of guilt of the accused
beyond reasonable doubt.
47.
Chavez vs. Commission on Elections
G.R. No. 162777. August 31, 2004

Police power, as an inherent attribute of sovereignty, is the power to

prescribe regulations to promote the health, morals, peace, education,
good order, or safety, and the general welfare of the people.