Photo from Unsplash | Ye Jinghan
The following post does not create a lawyer-client relationship between Alburo Alburo and Associates Law Offices (or any of its lawyers) and the reader. It is still best for you to engage the services of a lawyer or you may directly contact and consult Alburo Alburo and Associates Law Offices to address your specific legal concerns, if there is any.
Also, the matters contained in the following were written in accordance with the law, rules, and jurisprudence prevailing at the time of writing and posting, and do not include any future developments on the subject matter under discussion.
AT A GLANCE:
The rule is that an employee’s acquittal in a criminal case does not preclude a finding that he has been guilty of acts inimical to the employer’s interest.
The quantum of proof required [in an illegal dismissal case] is only substantial evidence. (MGG Marine Services, Inc. vs. NLRC, G.R. No. 114313, July 29, 1996)
In employment law, the interplay between criminal charges and employment status can be intricate and often misunderstood. A common misconception is that an employee’s acquittal in a criminal case automatically vindicates them of any wrongdoing in the workplace. However, this assumption overlooks the distinct legal principles governing criminal proceedings and employment disputes.
Quantum of Proof in Criminal Case
“Conviction in criminal actions demands proof beyond reasonable doubt. Rule 133, Section 2 of the Revised Rules on Evidence states:
Section 2. 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 as, excluding possibility of error, produces absolute certainty. Moral certainty only is required, or that degree of proof which produces conviction in an unprejudiced mind.” (Capistrano Daayata vs. People of the Philippines, G.R. No. 205745, March 8, 2017)
In criminal cases, the burden of proof lies with the prosecution, and guilt must be established beyond a reasonable doubt. This stringent standard requires the prosecution to prove the defendant’s guilt to a high degree of certainty, leaving no room for reasonable doubt. A verdict of “not guilty” or acquittal signifies that the prosecution failed to meet this demanding threshold, resulting in the exoneration of the accused.
Quantum of Proof in Illegal Dismissal Case
“The quantum of proof required in illegal dismissal cases is substantial evidence. This Court has already clarified that substantial evidence is only such evidence as a reasonable mind might accept as adequate to support a conclusion.
In this regard, it is a well-established rule that the party-litigant who alleges the existence of a fact or thing necessary to establish his/her claim has the burden of proving the same by the amount of evidence required by law, which, in labor proceedings, is substantial evidence, or “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”
Thus, in illegal dismissal cases, the employer need only present evidence which is adequate to support a conclusion, and not evidence which will establish moral certainty of guilt on the part of the employee.” (Philippine Long Distance Telephone Company vs. Cecilio Domingo, G.R. No. 197402, June 30, 2021)
On the other hand, illegal dismissal cases in labor law operate under a different standard of proof. The burden falls on the employer to justify the termination of employment, demonstrating that it was done in accordance with labor laws and regulations. However, this burden does not require the same level of certainty as in criminal cases. Instead, employers must provide substantial evidence to support their decision to terminate an employee, showing that it was for valid and lawful reasons
Why Acquittal Does Not Negate Finding of Illegal Dismissal
One key reason why an employee’s acquittal in a criminal case does not negate a finding of illegal dismissal lies in the distinct nature of these legal proceedings. While criminal charges may stem from the same set of circumstances as an employment dispute, they address different issues and are subject to different standards of proof.
In Lolita Concepcion vs. Minex Import Corporation (G.R. No. 153569, January 24, 2012), the Supreme Court clarified this principle. The Court emphasized that neither a criminal prosecution nor a conviction beyond reasonable doubt for a crime is a requisite for the validity of dismissal in an employment dispute. This ruling underscore the independence of labor proceedings from criminal matters and affirms that an employee’s acquittal does not automatically absolve the employer of liability for illegal dismissal.
In conclusion, the acquittal of an employee in a criminal case does not necessarily negate the finding of illegal dismissal in an employment dispute. While criminal proceedings require proof beyond a reasonable doubt, employment disputes hinge on substantial evidence of lawful termination.
Alburo Alburo and Associates Law Offices specializes in business law and labor law consulting. For inquiries regarding taxation and taxpayer’s remedies, you may reach us at info@alburolaw.com, or dial us at (02)7745-4391/0917-5772207.
All rights reserved.