Here are selected June 2010 rulings of the Supreme Court of the Philippines on political law:
Administrative cases; quantum of evidence. In administrative cases, the quantum of evidence necessary to find an individual administratively liable is substantial evidence. Substantial evidence does not necessarily mean preponderant proof as required in ordinary civil cases, but such kind of relevant evidence as a reasonable mind might accept as adequate to support a conclusion or evidence commonly accepted by reasonably prudent men in the conduct of their affairs. The evidence upon which respondent’s administrative liability would be anchored lacked that degree of certainty required in administrative cases, because the two separate audits conducted by the Commission on Audit yielded conflicting results. Evidence of shortage in respondent’s cash and accounts, as alleged in the first audit report, is imperative to hold him liable. In this case, the evidence against respondent could not be relied upon, because the second audit report, which was favorable to him, necessarily puts into question the reliability of the initial audit findings. Whether the zero balance as appearing in the second audit report was correct or inadvertently indicated, the credibility and accuracy of the two audit reports were already tarnished. Even in administrative cases, a degree of moral certainty is necessary to support a finding of liability. Office of the Ombudsman (Visayas) vs. Rodolfo Zaldarriaga, G.R. No. 175349, June 22, 2010.
Agrarian cases; just compensation. The taking of property under the Comprehensive Agrarian Reform Law (CARL) is a government exercise of the power of eminent domain. Since the determination of just compensation in eminent domain proceedings is a judicial function, a court proceeding to fix just compensation cannot be made to depend on the existence of, and is considered separate and independent from, an administrative case of a similar nature. Thus, the filing by the Land Bank of the Philippines (LBP) of a new petition for judicial determination of just compensation after the dismissal without prejudice of another LBP-initiated court proceeding on the same issue cannot be regarded as barred by the filing of the latter proceeding beyond the 15-day period prescribed under Rule XIII, Section 11 of the Rules of the Department of Agrarian Reform Adjudication Board (DARAB). Although the formula for fixing just compensation found in Section 17 of the CARL may be justly adopted in certain cases, it is by no means the only formula that the court may adopt in determining just compensation. Land Bank of the Philippines vs. Fortune Savings and Loan Association, Inc., represented by Philippine Deposit Insurance Corporation, G.R. No. 177511, June 29, 2010.
Due process; local autonomy; police power. Department of Agrarian Reform (DAR) Administrative Order No. 01-02, as amended, which sets out rules on land use conversion, does not violate the due process clause, because in providing administrative and criminal penalties, the Secretary of Agrarian Reform simply implements the provisions of the Comprehensive Agrarian Reform Law and the Agriculture and Fisheries Modernization Act, both of which provide penalties for illegal land conversion. Contrary to petitioner’s assertions, the penalties provided under DAR AO No. 01-02 are imposed upon the illegal or premature conversion of lands within DAR’s jurisdiction.