Hierarchy of evidentiary values
Evidence is what the parties in a case present in order to convince the court, tribunal or commission that the truth is on their side. Different questions of fact require different levels of proof. These levels of proof are called "quanta [plural of quantum] of evidence" or "hierarchy of evidentiary values." Depending on the jurisdiction, they are the following:
[1] No evidence;
[2] Scintilla of evidence;
[3] Reasonable suspicion;
[4] Probable cause;
[5] Substantial evidence;
[6] Preponderance of evidence;
[7] Clear and convincing evidence; and
[8] Proof beyond reasonable doubt.
[1] No evidence. No evidence is required when the law creates a presumption. For example, a man and a woman who present themselves as husband and wife are presumed to be legally married. No proof is required. Another example is that a law passed by Congress and signed by the President is presumed to be valid and constitutional.
[2] Scintilla of evidence. A scintilla of evidence is a particle of evidence that may be insignificant.
[3] Reasonable suspicion. Reasonable suspicion is a legal standard of proof in law that is less than probable cause, the legal standard for arrests and warrants, but more than an "inchoate and unparticularized suspicion or 'hunch'"; it must be based on "specific and articulable facts", "taken together with rational inferences from those facts", and the suspicion must be associated with the specific individual. https://en.wikipedia.org/wiki/Reasonable_suspicion
[4] Probable cause. A common definition is "a reasonable amount of suspicion, supported by circumstances sufficiently strong to justify a prudent and cautious person's belief that certain facts are probably true". Notable in this definition is a lack of requirement for public position or public authority of the individual making the recognition, allowing for use of the term by citizens and/or the general public. The definition of probable cause is, "(A) reasonable ground for supposing that a charge is well-founded" (Merriam-Webster, 2019). https://en.wikipedia.org/wiki/Probable_cause
Probable cause, for the purpose of filing a criminal information, has been defined as such facts as are sufficient to engender a well-founded belief that a crime has been committed and that respondent is probably guilty thereof. The term does not mean "actual and positive cause" nor does it import absolute certainty. It is merely based on opinion and reasonable belief. Probable cause does not require an inquiry into whether there is sufficient evidence to procure a conviction. It is enough that it is believed that the act or omission complained of constitutes the offense charged. (G.R. No. 172829. July 18, 2012)
Probable cause for a search warrant is defined as such facts and circumstances which would lead a reasonably discreet and prudent man to believe that an offense has been committed and that the objects sought in connection with the offense are in the place sought to be searched. (G.R. No. 110318. August 28, 1996) A search warrant shall not issue but upon probable cause in connection with one specific offense to be determined personally by the judge after examination under oath or affirmation of the complainant and the witnesses he may produce, and particularly describing the place to be searched and the things to be seized. (Rule 126 of the Rules of Court)
[5] Substantial evidence. Substantial evidence is defined as such amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion. (G.R. No. 131523. August 20, 1998)
[6] Preponderance of evidence. Preponderance of evidence simply means evidence that is of greater weight or more convincing than what is offered against it.10 In determining where the preponderance of evidence lies, the court may consider all the facts and circumstances of the case, such as: the witnesses’ demeanor, 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 their personal credibility so far as it may legitimately appear to the court. (September 2, 2015 G.R. No. 187727)
[7] Clear and convincing evidence. Clear and convincing proof is more than mere preponderance, but not to extent of such certainty as is required beyond reasonable doubt as in criminal cases while substantial evidence consists of more than a mere scintilla of evidence but may be somewhat less than a preponderance. Consequently, in the hierarchy of evidentiary values, We find proof beyond reasonable doubt at the highest level, followed by clear and convincing evidence, preponderance of evidence, and substantial evidence, in that order. (G.R. No. 102358 November 19, 1992)[8] Proof beyond reasonable doubt. In a criminal case, the accused is entitled to an acquittal, unless his guilt is shown beyond reasonable doubt. Proof beyond reasonable doubt does not mean such a degree of proof, excluding possibility of error, produces absolute certainly. Moral certainly only is required, or that degree of proof which produces conviction in an unprejudiced mind. (Rule 133, Section 2 of the Revised Rules on Evidence)
A conviction cannot be made to rest on imagination. The Constitution requires moral certainty or proof beyond reasonable doubt. The scant evidence on record cannot justify a leap to the conclusion that the "abuse" appellant perpetrated on Leah amounted to carnal knowledge under any of the three circumstances specified in Article 335 of the Revised Penal Code. (G.R. Nos. 144523-26 June 10, 2003)
In administrative law, determinations by executive agencies require only substantial proof and not clear and convincing evidence. The second is more than mere preponderance of evidence but not to the extent of such certainty as is required beyond reasonable doubt as in criminal cases, while the first consists of more than a mere scintilla of evidence but may be somewhat less than a preponderance.
It is a fundamental principle of administrative law that the administrative case may generally proceed against a respondent independently of a criminal action for the same act or omission and requires only substantial evidence to establish administrative guilt as against proof beyond reasonable doubt of the criminal charge.
The standard of substantial evidence is satisfied when there is a reasonable ground to believe that the person indicted was responsible for the alleged wrongdoing or misconduct. (520 SCRA 64)
Preponderance of evidence is meant simply evidence adduced by one side which is, as a whole, superior to or has greater weight or more convincing than that which is offered in opposition to it; at bottom, it means probability of truth. (454 SCRA 653)
He who alleged the affirmative of the issue has the burden of proof, and upon the plaintiff in a civil case, the burden of proof never parts. The same rule applies to administrative cases. However, in the course of trial in a civil case, once plaintiff makes out a prima facie case in his favor, the duty or burden of evidence shifts to defendant to controvert plaintiff's prima facie case; otherwise, a verdict must be returned in favor of plaintiff. Moreover, in civil cases, the party having the burden of proof must produce a preponderance of evidence thereon, with plaintiff having to rely on the strength of his own evidence and not upon the weakness of the defendant's. (487 SCRA 405)
Under the equipoise rule, where the evidence on an issue of fact is in equipoise (evenly balanced) or there is doubt on which side the evidence preponderates, the party having the burden of proof loses. (574 SCRA 737)
As long as the administrative findings are supported by substantial evidence, it is not the task of an appellate court to weigh once more the evidence submitted before the administrative body in respect of the sufficiency of such evidence.
[1] No evidence;
[2] Scintilla of evidence;
[3] Reasonable suspicion;
[4] Probable cause;
[5] Substantial evidence;
[6] Preponderance of evidence;
[7] Clear and convincing evidence; and
[8] Proof beyond reasonable doubt.
[1] No evidence. No evidence is required when the law creates a presumption. For example, a man and a woman who present themselves as husband and wife are presumed to be legally married. No proof is required. Another example is that a law passed by Congress and signed by the President is presumed to be valid and constitutional.
[2] Scintilla of evidence. A scintilla of evidence is a particle of evidence that may be insignificant.
[3] Reasonable suspicion. Reasonable suspicion is a legal standard of proof in law that is less than probable cause, the legal standard for arrests and warrants, but more than an "inchoate and unparticularized suspicion or 'hunch'"; it must be based on "specific and articulable facts", "taken together with rational inferences from those facts", and the suspicion must be associated with the specific individual. https://en.wikipedia.org/wiki/Reasonable_suspicion
[4] Probable cause. A common definition is "a reasonable amount of suspicion, supported by circumstances sufficiently strong to justify a prudent and cautious person's belief that certain facts are probably true". Notable in this definition is a lack of requirement for public position or public authority of the individual making the recognition, allowing for use of the term by citizens and/or the general public. The definition of probable cause is, "(A) reasonable ground for supposing that a charge is well-founded" (Merriam-Webster, 2019). https://en.wikipedia.org/wiki/Probable_cause
Probable cause, for the purpose of filing a criminal information, has been defined as such facts as are sufficient to engender a well-founded belief that a crime has been committed and that respondent is probably guilty thereof. The term does not mean "actual and positive cause" nor does it import absolute certainty. It is merely based on opinion and reasonable belief. Probable cause does not require an inquiry into whether there is sufficient evidence to procure a conviction. It is enough that it is believed that the act or omission complained of constitutes the offense charged. (G.R. No. 172829. July 18, 2012)
Probable cause for a search warrant is defined as such facts and circumstances which would lead a reasonably discreet and prudent man to believe that an offense has been committed and that the objects sought in connection with the offense are in the place sought to be searched. (G.R. No. 110318. August 28, 1996) A search warrant shall not issue but upon probable cause in connection with one specific offense to be determined personally by the judge after examination under oath or affirmation of the complainant and the witnesses he may produce, and particularly describing the place to be searched and the things to be seized. (Rule 126 of the Rules of Court)
[5] Substantial evidence. Substantial evidence is defined as such amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion. (G.R. No. 131523. August 20, 1998)
[6] Preponderance of evidence. Preponderance of evidence simply means evidence that is of greater weight or more convincing than what is offered against it.10 In determining where the preponderance of evidence lies, the court may consider all the facts and circumstances of the case, such as: the witnesses’ demeanor, 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 their personal credibility so far as it may legitimately appear to the court. (September 2, 2015 G.R. No. 187727)
[7] Clear and convincing evidence. Clear and convincing proof is more than mere preponderance, but not to extent of such certainty as is required beyond reasonable doubt as in criminal cases while substantial evidence consists of more than a mere scintilla of evidence but may be somewhat less than a preponderance. Consequently, in the hierarchy of evidentiary values, We find proof beyond reasonable doubt at the highest level, followed by clear and convincing evidence, preponderance of evidence, and substantial evidence, in that order. (G.R. No. 102358 November 19, 1992)[8] Proof beyond reasonable doubt. In a criminal case, the accused is entitled to an acquittal, unless his guilt is shown beyond reasonable doubt. Proof beyond reasonable doubt does not mean such a degree of proof, excluding possibility of error, produces absolute certainly. Moral certainly only is required, or that degree of proof which produces conviction in an unprejudiced mind. (Rule 133, Section 2 of the Revised Rules on Evidence)
A conviction cannot be made to rest on imagination. The Constitution requires moral certainty or proof beyond reasonable doubt. The scant evidence on record cannot justify a leap to the conclusion that the "abuse" appellant perpetrated on Leah amounted to carnal knowledge under any of the three circumstances specified in Article 335 of the Revised Penal Code. (G.R. Nos. 144523-26 June 10, 2003)
In administrative law, determinations by executive agencies require only substantial proof and not clear and convincing evidence. The second is more than mere preponderance of evidence but not to the extent of such certainty as is required beyond reasonable doubt as in criminal cases, while the first consists of more than a mere scintilla of evidence but may be somewhat less than a preponderance.
It is a fundamental principle of administrative law that the administrative case may generally proceed against a respondent independently of a criminal action for the same act or omission and requires only substantial evidence to establish administrative guilt as against proof beyond reasonable doubt of the criminal charge.
The standard of substantial evidence is satisfied when there is a reasonable ground to believe that the person indicted was responsible for the alleged wrongdoing or misconduct. (520 SCRA 64)
Preponderance of evidence is meant simply evidence adduced by one side which is, as a whole, superior to or has greater weight or more convincing than that which is offered in opposition to it; at bottom, it means probability of truth. (454 SCRA 653)
He who alleged the affirmative of the issue has the burden of proof, and upon the plaintiff in a civil case, the burden of proof never parts. The same rule applies to administrative cases. However, in the course of trial in a civil case, once plaintiff makes out a prima facie case in his favor, the duty or burden of evidence shifts to defendant to controvert plaintiff's prima facie case; otherwise, a verdict must be returned in favor of plaintiff. Moreover, in civil cases, the party having the burden of proof must produce a preponderance of evidence thereon, with plaintiff having to rely on the strength of his own evidence and not upon the weakness of the defendant's. (487 SCRA 405)
Under the equipoise rule, where the evidence on an issue of fact is in equipoise (evenly balanced) or there is doubt on which side the evidence preponderates, the party having the burden of proof loses. (574 SCRA 737)
As long as the administrative findings are supported by substantial evidence, it is not the task of an appellate court to weigh once more the evidence submitted before the administrative body in respect of the sufficiency of such evidence.