In the case of Spouses Boyboy vs. Atty. Yabut, Jr., A.C. No. 5225.

April 29,
2003, the Supreme Court said, “We must emphasize that a mere charge or allegation of
wrongdoing does not suffice. Accusation is not synonymous with guilt. There must
always be sufficient evidence to support the charge.

Under paragraph Z of Section 1, Rule 2 of NAPOLCOM Memorandum Circular

No. 2007-001, substantial evidence has been defined as such relevant evidence as a
reasonable mind might accept as adequate to support a conclusion.

The Supreme Court in the case of Marcelo vs. Bungubung, G.R. No. 175201,
April 23, 2008, citing the case of Montemayor v. Bundalian, the Court held:

“The burden is on the complainant to prove by substantial evidence the

allegations in his complaint. Substantial evidence is more than a mere scintilla of
evidence. It means such relevant evidence as a reasonable mind might accept as
adequate to support a conclusion, even if other minds equally reasonable might
conceivably opine otherwise.

Further in the case of Dr. De Jesus vs. Guerrero III, et al., G.R. No. 171491,
September 4, 2009, the Supreme Court held that “The complainant has the burden of
proving by substantial evidence the allegations in his complaint. The basic rule is that
mere allegation is not evidence and is not equivalent to proof. Charges based on mere
suspicion and speculation likewise cannot be given credence. Hence, when the
complainant relies on mere conjectures and suppositions, and fails to substantiate his
allegations, the administrative complaint must be dismissed for lack of merit.”