Good faith is always presumed under the Rules of Evidence, especially in respect of the actions of public officials, who, under the Rules of Evidence, are entitled to the PRESUMPTION OF REGULARITY IN THE PERFORMANCE OF PUBLIC DUTY.
In the case of Heirs of Severa Gregorio vs. Court of Appeals, et al, G. R. No. 117609, December 19, 1998, the Supreme Court held that “it is axiomatic that good faith is always presumed unless convincing evidence to the contrary is adduced”; that “it is incumbent upon the party alleging bad faith to sufficiently prove such allegation”; that “absent enough proof thereof, the presumption of good faith prevails”; that “without a clear and persuasive substantiation of bad faith, the presumption of good faith in favor of respondents stands”.
In the case of FRANCISCO M. LECAROZ, et. al. vs. SANDIGANBAYAN, et. al., G.R. No. 130872, March 25, 1999, it was held that “the rule is that any mistake on a doubtful or difficult question of law may be the basis of good faith”; that “an erroneous interpretation of the meaning of the provisions of an ordinance (or a law or an administrative procedure) does not amount to bad faith”; that “public officials may not be liable for damages in the discharge of their official functions absent any bad faith”; and that “under the law on public officers, acts done in the performance of official duty are protected by the presumption of good faith.”
In the case of ALBERT S. DELA PEÑA vs. ILUMINADO R. HUELMA, A.M. No. P-06-2218, Aug. 15, 2006, it was held that “in administrative proceedings, the burden of proof that the respondent committed the act complained of rests on the complainant”; that “the complainant must be able to show this by substantial evidence, or such relevant evidence as a reasonable mind might accept as adequate to support a conclusion, otherwise, the complaint must be dismissed”; that the complainant “in his complaint relied on too many assumptions unsupported by evidence”.
In the case of People vs. De Guzman, GR 106025, Feb. 9, 1994, it was held that “the presumption is that an official act or duty has been regularly performed”; that the reasons behind such a presumption are as follows:
(1) Innocence, and not wrong-doing, is presumed.
(2) Good faith is presumed;
(3) Presumption that an official oath will not be violated;
(4) The republican system of government cannot survive unless a certain trust and confidence is reposed in each government department or agent.
The aforecited case further held that the presumption of regularity “may be rebutted by affirmative evidence of irregularity or failure to perform duty”; that the “presumption prevails until it is overcome by clear and convincing evidence to the contrary”; that “if not rebutted, it is conclusive”; and that “in case of doubt, statutory construction is in favor of the lawfulness of the act of a public official”.
