Fact: Petitioner is the Training Coordinator of NIACONSULT, INC., a subsidiary of the National Irrigation Administration. K.N. Paudel of the Agricultural Development Bank of Nepal (ADBN) Mote a letter to NIACONSULT requesting a training proposal on small-scale community irrigation development. Petitioner as the training coordinator of the NIACONSULT, sent a letter-proposal requested by ABDN. Another letter was sent by petitioner on January 31, 1989 to Dr. Peiter Roeloffs of ADBN confirming the availability of NIACONSULT to conduct the training program and formally requesting advance payment of thirty (30%) percent of the training fee in the amount of US $9,600.00 or P204,960.00. NIACONSULT conducted the training program for six Nepalese Junior Engineers from February 6 to March 7, 1989. ADBN, thru its representative, Deutsche Gesselschaft Technische Zusummenarbeit (GTZ) Gmbh Technical Cooperation of the Federal Republic of Germany paid to the petitioner the agreed training fee in two installments of P61,488.00 and P143, 472.00. On April 1, 1991, NIACONSULT, through its president, Wilfredo S. Tiongco, wrote a letter to petitioner demanding the turn-over of the total training fee paid by ADBN which petitioner personally received. Despite receipt of the letter, petitioner failed to remit the said amount prompting NIACONSULT through its president, Maximino Eclipse, to file an administrative case before respondent OMBUDSMAN for serious misconduct and/or fraud or willful breach of trust.
While the case is pending, petitioner filed a Manifestation on May 24, 1997 stating that the criminal complaint for estafa and falsification filed against him based on the same facts or incidents which gave rise to the administrative case, was dismissed by the Regional Trial Court on February 24, 1997. With the dismissal of the criminal case, petitioner manifests that the administrative case can no longer stand on its own and therefore should be dismissed.
Issue: Whether the dismissal of the Petitioner’s of the Criminal Case warrants dismissal of the Criminal Case?
Held: No, The dismissal of the criminal case will not foreclose administrative action filed against petitioner or give him a clean bill of health in all respects. The Regional Trial Court, in dismissing the criminal complaint, was simply saying that the prosecution was unable to prove the guilt of petitioner beyond reasonable doubt, a condition sine qua non for conviction. The lack or absence of proof beyond reasonable doubt does not mean an absence of any evidence whatsoever for there is another class of evidence which, though insufficient to establish guilt beyond reasonable doubt, is adequate in civil cases; this is preponderance of evidence. Then too, there is the “substantial evidence” rule in administrative proceedings which merely requires such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.18 Thus, considering the difference in the quantum of evidence, as well as the procedure followed and the sanctions imposed in criminal and administrative proceedings, the findings and conclusions in one should not necessarily be binding on the other.
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