Joephil Bien v. Pedro Bo
G.R. No. 179333, August 3, 2010

Facts: Bo filed a complaint before the Ombudsman against barangay officials of San Isidro, including Bien, for the destruction of his cottage and coconut plantation. He insists that Bien and the other barangay officials connived in doing so in order to construct their own private cottages for their own benefit.

The Ombudsman found Bien and the other barangay officials administratively liable for abuse of authority.

Issue: Whether or not the administrative liability of Bien, et. al. should be upheld despite failure to prove their participation in the said destruction.

Held: Yes. In administrative cases, the requisite proof is substantial evidence, i.e., that amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion. In the case at bar, substantial evidence consisted in the findings of the DENR-PENRO identifying petitioner as one of the owners of the twenty-two (22) cottages illegally erected on the subject property covered by a lease application of respondent. The Final Report of the DENR-PENRO narrates the circumstances surrounding the conflict between respondent and the barangay officials of San Isidro Ilawod, concerning respondent application for lease of the subject property.