In Nicolas v. National Labor Relations Commission,[327 Phil.

883, 886-887 (1996)

.] we held that a criminal conviction is not necessary to find just cause for em
ployment termination.
Criminal cases require proof beyond reasonable doubt while labor disputes requir
e only substantial evidence, which means such relevant evidence as
a reasonable mind might accept as adequate to justify a conclusion.
See Patna-an v. National Labor Relations Commission, G.R. No. 92878, March 6, 19
92, 207 SCRA 106; Iriga Telephone Co., Inc. v. National Labor Relations Commissi
on, 350 Phil. 245, 253 (1998).