Practice question
An administrative disciplinary tribunal provides notice and a fair opportunity to submit evidence. It independently assesses the disclosed record and explains its findings. The respondent argues that a finding supported by substantial evidence must nonetheless be void solely because the tribunal did not use proof beyond reasonable doubt as its administrative standard. No rule requiring that criminal standard applies. Which assessment follows Ang Tibay?
- Every administrative finding needs a criminal conviction first
- The stipulated administrative substantial-evidence standard is not automatically displaced by the criminal proof standard
- No evidence is required in administrative adjudication
- The respondent’s denial is always conclusive
- Administrative findings may be based solely on secret suspicion
Legal references
- Ang Tibay v. Court of Industrial Relations, G.R. No. 46496, February 27, 1940, main opinion: https://lawphil.net/judjuris/juri1940/feb1940/gr_46496_1940.html
- Zoleta v. Investigating Staff, G.R. No. 258888, April 8, 2024, main decision: https://lawphil.net/judjuris/juri2024/apr2024/gr_258888_2024.html
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