"Probable cause" doesn't mean you're guilty
The determination of probable cause needs only to rest on evidence showing
that more likely than not, a crime has been committed and there is enough
reason to believe that it was committed by the accused.[1] It need not be
based on clear and convincing evidence of guilt, neither on evidence
establishing absolute certainty of guilt.[2] What is merely required is
"probability of guilt." Its determination, too, does not call for the
application of rules or standards of proof that a judgment of conviction
requires after trial on the merits.[3] Thus, in concluding that there is
probable cause, it suffices that it is believed that the act or omission
complained of constitutes the very offense charged.
It is also important to stress that the determination of probable cause does
not depend on the validity or merits of a party’s accusation or defense, or on
the admissibility or veracity of testimonies presented. As previously
discussed, these matters are better ventilated during the trial proper of the
case.[4] As held in Metropolitan Bank & Trust Company v.
Gonzales:[5]
It is also important to stress that the determination of probable cause does
not depend on the validity or merits of a party’s accusation or defense, or on
the admissibility or veracity of testimonies presented. As previously
discussed, these matters are better ventilated during the trial proper of the
case.[4] As held in Metropolitan Bank & Trust Company v.
Gonzales:[5]
Probable cause has been defined as the existence of such facts and circumstances as would excite the belief in a reasonable mind, acting on the facts within the knowledge of the prosecutor, that the person charged was guilty of the crime for which he was prosecuted. xxx The term does not mean "actual or positive cause" nor does it import absolute certainty. It is merely based on opinion and reasonable belief.
Thus, a finding of 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. Precisely, there is a trial for the reception of evidence of the prosecution in support of the charge.
[1] Galario v. Office of the Ombudsman (Mindanao), 554 Phil. 86, 101 (2007).
[2] Casing v. Ombudsman, G.R. No. 192334, June 13, 2012, 672 SCRA 500, 509.
[3] Ricaforte v. Jurado, 559 Phil. 97, 109 (2007).
[4] Lee v. KBC Bank N.V., G.R. No. 164673, January 15, 2010.
[5] G.R. No. 180165, April 7, 2009, 584 SCRA 631, 640-641.