The rule in labor cases is that the employer has the burden of proving that the dismissal was for a just cause; failure to show this would necessarily mean that the dismissal was unjustified and, therefore, illegal.[17]  The two-fold requirements for a valid dismissal are as follows:  (1) dismissal must be for a cause provided for in the Labor Code, which is substantive; and (2) the observance of notice and hearing prior to the employee’s dismissal, which is procedural.[18]              The only evidence relied upon by petitioner in justifying respondent’s dismissal is the Chief Engineer’s Report datedSeptember 10, 1997.  The question that arises, therefore, is whether the Report constitutes substantial evidence proving that respondent’s dismissal was for cause.    Substantial evidence is defined as that amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion.[19]  As all three tribunals found, the Report cannot be given any weight or credibility because it is uncorroborated, based purely on hearsay, and obviously merely an afterthought.   While rules of evidence are not strictly observed in proceedings before administrative bodies,[20] petitioner should have offered additional proof to corroborate the statements described therein.  Thus, in Ranises v. National Labor Relations Commission,[21] involving a seafarer who was repatriated to thePhilippines for allegedly committing illegal acts amounting to a breach of trust, as based on a telex dispatch by the Master of the M/V Southern Laurel, the Court rejected the weight given by the NLRC on the telex, to wit:   Unfortunately, the veracity of the allegations contained in the aforecited telex was never proven by respondent employer.  Neither was it shown that respondent  employer exerted any effort to even verify the truthfulness of Capt. Sonoda’s report and establish petitioner’s culpability for his alleged illegal acts.  Worse, no other evidence was submitted to corroborate the charges against petitioner.  

Select target paragraph3