G.R. No. 181796 - REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE DIRECTOR/HEAD OF THE CRIMINAL INVESTIGATION AND DETECTION GROUP (CIDG), PHILIPPINE NATIONAL POLICE (PNP), V. REGINA N. CAYANAN AND SPO1 ROLANDO V. PASCUA.

Ruling

Accordingly, we shall also determine herein the sufficiency of the evidence presented in support of the petition for the issuance of the writ of amparo . I. Substantial evidence existed to warrant the issuance of the writ of amparo Section 1 of the Rule on the Writ of Amparo defines the nature of the writ of amparo as a remedy against enforced disappearances or threats to life, liberty and personal security, viz .: Section 1. Petition . - The petition for a writ of amparo is a remedy available to any person whose right to life, liberty and security is violated or threatened with violation by an unlawful act or omission of a public official or employee, or of a private individual or entity. The writ shall cover extralegal killings and enforced disappearances or threats thereof. Section 17 of the Rule on the Writ of Amparo specifies the degree of proof required from the petitioner as a respondent named in the petition for the writ of amparo , to wit: Section 17. Burden of Proof and Standard of Diligence Required. - The parties shall establish their claims by substantial evidence . xxxx Section 18 of the Rule on the Writ of Amparo requires substantial evidence to establish the allegations of the petition for the writ of amparo and to warrant granting the privilege of the writ of amparo , to wit: Section 18. Judgment . - x x x If the allegations in the petition are proven by substantial evidence , the court shall grant the privilege of the writ and such reliefs as may be proper and appropriate; otherwise , the privilege shall be denied . Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. [18] This standard was applied in Secretary of National Defense v. Manalo , [19] the first ruling by the Court relating to the remedy of the writ of amparo . In Razon, Jr. v. Tagitis , [20] a case involving the propriety of the trial court's issuance of the writ of amparo , the Court expounded on the need for substantial evidence to support the petition for the writ of amparo , viz.: We see no merit in the petitioners' submitted position that no sufficient evidence exists to support the conclusion that the Kasim evidence unequivocally points to some government complicity in the disappearance x x x. We painstakingly ruled: To give full meaning to our Constitution and the rights it protects, we hold that, as in Velasquez , we should at least take a close look at the available evidence to determine the correct import of every piece of evidence - even of those usually considered inadmissible under the general rules of evidence - taking into account the surrounding circumstances and the test of reason that we can use as basic minimum admissibility requirement x x x. xxxx Likewise, we see no merit in the petitioners' claim that the Kasim evidence does not amount to substantial evidence required by the Rule on the Writ of Amparo . This is not a new issue; we extensively and thoroughly considered and resolved