REPUBLIC OF THE PHILIPPINES CONGRESS OF THE PHILIPPINES SENATE SITTING AS THE IMPEACHMENT COURT

IN THE MATTER OF THE IMPEACHMENT OF RENATO C. CORONA AS CHIEF JUSTICE OF THE SUPREME COURT OF THE PHILIPPINES, CASE NO. 002-2011 REPRESENTATIVES NIEL C. TUPAS, JR., JOSEPH EMILIO A. ABAYA, LORENZO R. TAÑADA, III, REYNALDO V. UMALI, ARLENE J. BAG-AO (other complainants comprising one third (1/3) of the total Members of the House of Representatives as are indicated below.)
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COMPLIANCE
The HOUSE OF REPRESENTATIVES, through its PROSECUTORS, respectfully submits the instant Compliance to the Order1 of the Honorable Tribunal rendered on 24 January 2012 requiring the Prosecutors to submit a list of witnesses and documentary evidence to be presented in the course of the trial (in addition to those already presented thus far).2

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TSN, January 24, 2012, p. 7. The Order rendered by the Honorable Tribunal required both parties to submit, within three (3) days, a written list of the names of the witnesses and the substance of their testimonies, as well as a list of the documentary exhibits. 2 This list presumes that the defense will not be willing to stipulate on the documents subject matter of the witnesses’ testimonies.

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ARTICLE I
List of Witnesses

1.

Mr. Marianito Dimaandal, Head, Records Office, Office of the President,

Malacañang, Manila - He will identify CJ Corona’s Service Records with then Vice President and later President, Gloria Macapagal Arroyo, and testify in relation thereto. 2. Atty. Enriqueta Vidal, Clerk of Court, Supreme Court – She will identify CJ

Corona’s Service Records as Associate Justice and later as Chief Justice of the Supreme Court, and testify in relation thereto. 3. Prof. Harry Roque, Director, U.P. Law Center, Diliman, Quezon City He

will testify as an expert witness on the voting record of CJ Corona as a Member of the Supreme Court to prove his partiality and subservience to former President Gloria M. Arroyo, both when she was President and later after she ceased to be one. 4. Undersecretary Jose Luis C. Gascon, Malacañang, Manila - He will testify as a

Member of the 1986 Constitutional Commission that drafted the present Constitution on the origin, backgroud and rationale for the midnight appointments ban under Article VII, Sec. 15 of the Constitution and on Betrayal of Public Trust as an impeachable offense under Article XI, Sec. 2 of the Constitution. 5. Ms. Donna Z. Pazzibugan, Philippine Daily Inquirer, Chino Roces Avenue corner

Yague and Mascardo Streets, Makati City. - As a Malacañang accredited reporter for the PDI, she will testify and prove that during the oath-taking of CJ Corona in Malacañang Palace on May 17, 2010 the public and even the accredited media were barred. 6. Ms. Emma Rey, Executive Director, Congressional Library Bureau, House of

Representatives, Batasan Hills, Quezon City - She will identify certain parts of the Records of the 1986 Constitutional Commission and testify in relation thereto.

Documentary Evidence A. With reference to the testimony of Mr. Marianito Dimaandal

3 1. Certified true copies of the Service Records of CJ Corona as Chief of Staff and Spokesperson of then Vice President Gloria M. Arroyo, and later as Chief of Staff and Spokesperson of then President Gloria M. Arroyo as well as Acting Executive Secretary of then President Gloria M. Arroyo. B. With reference to the testimony of Atty. Enriqueta Vidal 1. Certified true copies of the Service Records of CJ Corona as Associate Justice (April 9, 2002 to May 16, 2010) and as Chief Justice (May 17, 2010 to present). C. With reference to the testimony of Prof. Harry Roque 1. Chart/table showing the voting pattern of the respondent as a Member of the Supreme Court.

D.

With reference to the testimony of Undersecretary Jose Luis C. Gascon 1. Certified photocopies of portions of the Records of the Constitutional Commission.

E.

With reference to the testimony of Ms. Donna Z. Pazzibugan 1. PDI issue of May 18, 2010

F.

With reference to the testimony of Ms. Emma Rey 1. Certified photocopies of portions of the Records of the Constitutional Commission.

ARTICLE II
List of Witnesses 1. Register of Deeds of Makati City - He will testify on the Condominium

Certificate of Title and Deed of Absolute Sale pertaining to condominium unit purchased by Renato C. Corona and Cristina R. Corona in The Columns Ayala Avenue. 2. Mr. Giovanni Ng, Finance Director/representative of Megaworld Corp. - He will

testify on the purchase of Renato Corona and Cristina Corona of a penthouse (with three

4 parking slots) at The Bellagio Condominium, and of a lot at McKinley Hill Village, as well as on the circumstances and particulars of said sale transactions. 3. Mr. Aniceto Visnar, Jr., representative of Ayala Land - He will testify on the

purchase of Renato C. Corona and Cristina R. Corona of the Bonifacio Ridge condominium unit. 4. Ms. Nerissa H. Josef, representative of Community Innovations, Inc. - She will

testify on the purchase of Renato C. Corona and Cristina R. Corona of The Columns condominium unit. 5. Mr. Greg Gregonia, representative of Burgundy Realty Corporation - He will

testify on the purchase of Renato C. Corona and Cristina R. Corona of Burgundy Katipunan condominium unit. 6. Records Officer of John Hay Management Corp. - He/she will testify on the SALN

filed, if any, by Cristina R. Corona at the John Hay Management Corp. 7. Representative of National Statistics Office (NSO) - He/she will testify on the

Certificate of Live Birth of Ma. Carla R. Corona-Castillo and Ma. Charina R. Corona and the Marriage Certificate/Contract of Ma. Carla R. Corona-Castillo and Constantino Castillo III. 8. Director, Corporate Registration and Monitoring Dept. of SEC - He/she will

testify on the SEC records of Basa-Guidote Enterprises, Inc. 9. Representative of Housing Land Use Regulatory Board - He/she will testify on

the records on file of the following projects: The Bellagio, Bonifacio Ridge, Mckinley Hill and Burgundy Plaza Katipunan. 10. Corona. 11. Ms. Mary Eleonor A. Mendoza, Vice-President, Filinvest Alabang, Inc. - She will Bank Representatives of BPI, PNB and Land Bank - They will testify on the

existence, transactions and balances of the bank accounts of Renato C. Corona and Cristina R.

testify on the execution of the Contract To Sell Common Share between Filinvest Alabang, Inc. and Spouses Renato C. Corona and Cristina R. Corona dated July 14, 2006 covering one (1) common share of The Palms Country Club, Inc.

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12.

Ms. Ava Venus A. Mejia, Vice President - Finance, Filinvest Alabang, Inc. - She

will testify on the execution of the Deed of Sale of Common Share between Filinvest Alabang, Inc. and Spouses Renato C. Corona and Cristina R. Corona notarized on September 11, 2009 covering one (1) common share of the The Palms Country Club, Inc. 13. Certified Fraud Examiner (CFE) - He/she will render expert opinion on the true or

correct Net Worth of Renato C. Corona and his incapacity to acquire the properties registered under his name and that of his wife and children based on his declared income.

Documentary Evidence A. With reference to The Columns property to be testified to by The Register of Deeds of Makati City and Nerissa J. Josef 1. Condominium Certificate of Title No. 85716 in the name of Cristina R. Corona; 2. Deed of Absolute Sale between Community Innovations, Inc. and Cristina R. Corona dated October 1, 2004; 3. 4. 5. 6. Buyer’s Information Sheet; Contract To Sell; Various Official Receipts; and Deed of Absolute Sale.

B.

With reference to The Bellagio and McKinley property to be testified to by Giovanni Ng 1. Deeds of Absolute Sale pertaining to the purchase of The Bellagio unit and Mckinley Hill lot; 2. 3. 4. 5. Contract to Buy and Sell; Request for Reservation and Offer to Purchase; Various Official Receipts; Deed of Assignment;

6 6. 7. Letter-request dated September 8, 2004; and Buyer’s Information Sheet.

C.

With reference to the Bonifacio Ridge property to be testified to by Aniceto Visnar Jr. 1. 2. 3. 4. Buyer’s Information Sheet; Various Official Receipts; Deed of Absolute Sale; and Certificate Authorizing Registration and Documentary Stamp Tax Declaration.

D.

With reference to the Burgundy property to be testified to be Greg Gregonia 1. 2. 3. 4. 5. 6. 7. Reservation Application; Contract To Sell; Statement of Account with Various Official Receipts; Deed of Absolute Sale; Acknowledgement of Unit Completion and Acceptance; Agreement to Allot Parking Slot; and Certificate Authorizing Registration.

E.

With reference to the testimony of the Records Officer of John Hay Management Corp. 1. Statement of Assets, Liabilities and Net Worth of Cristina R. Corona.

F.

With reference to the testimony of the representative of the National Statistics Office 1. 2. 3. Certificate of Live Birth of Ma. Carla R. Corona-Castillo; Certificate of Live Birth of Ma. Charina R. Corona ; and Marriage Contract of Ma. Carla R. Corona-Castillo and Constantino Castillo III.

G.

With reference to Basa-Guidote Enterprises Inc. to be testified to by the Director of the Corporate, Registration and Monitoring Department of the Securities and Exchange Commission

7 1. 2. 3. 4. H. Articles of Incorporation General Information Sheets (GIS) Audited Financial Statements Other documents

With reference to the testimony of the Representative of the Housing Land Use Regulatory Board 1. 2. 3. 4. Records on file of The Bellagio; Records on file of Bonifacio Ridge; Records on file of Mckinley Hill; and Records on file of Burgundy Plaza Katipunan.

I.

With reference to the testimony of the representatives of BPI, PNB and Land Bank 1. Account Opening Forms completed by Renato C. Corona and Cristina R. Corona; and 2. Monthly Bank Statements of Renato C. Corona and Cristina R. Corona.

J.

With reference to the sale of the one (1) common share of The Palms Country Club between Filinvest Alabang, Inc. and Sps. Renato C. Corona and Cristina R. Corona 1. Contract To Sell Common Share between Filinvest Alabang, Inc. and Spouses Renato C. Corona and Cristina R. Corona dated July 14, 2006 covering one (1) common share of The Palms Country Club, Inc.; 2. Deed of Sale of Common Share between Filinvest Alabang, Inc. and Spouses Renato C. Corona and Cristina R. Corona notarized on September 11, 2009 covering one (1) common share of the The Palms Country Club, Inc.; 3. The Palms Country Club Class “A” Share No. 000891 in the name of Filinvest Alabang, Inc.; and 4. The Palms Country Club “Class “A” Share issued to Spouses Renato C. Corona and Cristina R. Corona.

8 K. With reference to the testimony of the Certified Fraud Examiner pertaining to his opinion as to the truthfulness of the Net Worth of Renato C. Corona and his incapacity to acquire the properties registered in his name and his spouse’s that were also presented before this Honorable Tribunal 1. Expert Opinion Report

ARTICLE III
List of Witnesses 1. Atty. Gorgonio B. Elarmo Jr. - He will identify and authenticate the following: (a)

the original and certified true copy of the Authorization Letter dated 23 November 2010 authorizing Ms. MICHELLE M. MANGUBAT to hold a cash advance in the amount of P100,000.00 to be used to purchase Christmas gifts of the Chief Justice; and (b) all other requests, authorizations, approvals and such other documents pertaining to cash advances given to Chief Justice Renato C. Corona. 2. Ms. Michelle M. Mangubat, Special Disbursing Officer and/or the SC Resident

COA Auditor - She will identify and authenticate the original and certified true copies of official receipts/disbursement vouchers of meals, gifts, personal expenses of CJ Corona which were charged to the Supreme Court. 3. Ms. Corazon G. Ferrer-Flores - She will identify and authenticate: (a) the original

and certified true copies of the “MEMORANDUM FOR: HON. RENATO C. CORONA” dated July 16, 2010 on the “Proposed Augmentation of Gasoline Expense Allowance”, and all other memoranda for gas allowances given to the Chief Justice from July 16, 2010 up to the present and such other pertinent documents relating to the preparation, disbursement and liquidation of this item; and (b) Pertinent documents such as but not limited to disbursement vouchers on the gasoline allowances paid to Chief Justice Corona covering the period from June 1, 2010 up to the present. 4. The Authorized Officer of EDSA Shangrila Plaza - He/she will identify and

authenticate the original and certified true copies of: (a) Official Receipt “OR No: 102768 Date: 06/16/2011 As per transaction # 60187 / 422 RECEIVED from Supreme Court” in the amount of P61,740.73 with attached Rustan’s Itemized List consisting of nineteen (19) items; and (b) the pertinent Bridal/Gift registry on the 60th Wedding Anniversary of James and Julie Dy, and (c) other pertinent documents pertaining to this transaction on file with Rustan’s Office.

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5.

The Owner/Manager Authorized Representative of Design Exchange Inc. –

He/she will identify and authenticate the original and certified true copies of: (a) Design EXCHANGE Incorporated Sales Invoice No. 4874 dated June 10, 2010 under the name “ c/o CRISTINA CORONA CJ RENATO CORONA” amounting to P20,400; and (b) Design EXCHANGE Incorporated Sales Invoice No. 4920 dated June 29, 2010 under the name “RENATO CORONA CRISTINA CORONA” amounting to P25,000; 6. The Corporate Secretary or Assistant Corporate Secretary of John Hay - He/she will provide a short corporate background of JHMC and

Management Corporation

the election of Mrs. Cristina Corona as President and Chair of JHMC. She will also produce the subpoenaed documents such as the Minutes of the Board Meeting held on April 3, 2007 during which Mrs. Corona was elected Chair and President, and the letters of Executive Secretary Eduardo Ermita to BCDA Chair Aloysius Santos with the desire letters from President Gloria M. Arroyo. 7. Atty. Lyssa GS Pagano Calde (Former Vice President and COO of JHMC) She

will testify to prove the abuses of Mrs. Corona and her dismal performance as Chair and President of JHMC to prove that, notwithstanding those abuses and dismal performance, Mrs. Corona was untouchable.. 8. Retired Court of Appeals Justice Teodoro P. Regino - He will testify to

prove that the Board of Directors withdrew the election of Mrs. Corona as Chairman and President and declared the positions vacant due to irregularities/anomalies committed by Mrs. Corona. He will further testify and prove that Former President Gloria M. Arroyo has ordered all members of the Board to submit instead their resignations and he will testify regarding his letter of resignation dated June 20, 2007. 9. COA Director Ma. Cristina Dizon-Dimagiba - She will testify to show the

questionable/irregular expenditures incurred by Mrs. Corona for the year ending 2007 and to prove that, notwithstanding those irregularities, Mrs. Corona was untouchable. 10. COA Director Rosemarie Lacson-Lerio - She will testify to show the

questionable/irregular expenditures incurred by Mrs. Corona continued for the years 2008 and 2009 proving further that Mrs. Corona was truly untouchable. 11. COA Supervising Auditor Atty. Arlyn M. Encarnacion - She will testify to show

that, after Mrs. Corona resigned on July 10, 2012, and a new President took over, the

10 questionable/irregular expenditures heretofore committed by Mrs. Corona stopped. 12. Secretary of Judicial Bar and Council- He/she will testify to prove that during the

interview of respondent by the JBC on April 21, 2010, relative to his application for Chief Justice, Mrs. Corona’s employment was questioned. He/she will also testify on the other objections submitted against the nomination/appointment of respondent as Associate Justice and Chief Justice. 13. Mr. Frank Daytec3 (Former Operations Manager of JHMC) - He will testify to

prove that respondent and Mrs. Corona were complicit in the misuse of funds owned by JHMC. 14. Mr. Lauro Vizconde - His testimony will show that CJ Corona met with him and

Mr. Dante Jimenez sometime in September 2010. During said meeting, CJ divulged information regarding his pending case. 15. Mr. Dante Jimenez - His testimony will corroborate the testimony of Mr.

Vizconde that CJ Corona met with them in the latter’s chamber sometime in September 2010. During said meeting, CJ divulged information regarding Mr. Vizconde’s case. 16. Professor Rosario Maria T. Juan-Bautista - She will testify on what are the

nature, scope and rationale behind the constitutional provision, code of judicial conduct, and code of judicial ethics, which mandate that justices and judges of courts must be of proven competence, integrity, probity and independence. She will also testify on what are considered violations of the constitution, code of judicial conduct, and code of judicial ethics.

17.

Mr. Roberto Anduiza, FASAP President - He will testify on the status of FASAP

case, and the two decisions in favor of FASAP. He will also testify on the circumstances concerning the recall of the decision, specially the failure to notify FASAP about Atty. Mendoza’s letters as well as the circumstances concerning FASAP’s letter-appeal to the Supreme Court and the direct effect of the recall of the FASAP decision on the FASAP members who are parties in the case. 18. Court Administrator Jose Midas Marquez - Statements that he made to media

regarding the recall of the FASAP decision as well as the source/s of his information on the reasons for the recall of the decision.
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Mr. Daytec filed a criminal case against Mrs. Corona and the Respondent; the case docketed as Frank Daytec vs. Ma. Cristina Corona and Renato Corona, NPS Docket No. XVI-INV-11G-00247 is pending preliminary investigation at the DOJ.

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19.

Atty. Enriqueta Esguerra-Vidal, Clerk of Court of the SC - She will testify on the

circumstances of the transfer of the FASAP case from one division to another. She will identify the Memorandum dated September 26, 2011, prepared by her office (through deputy Clerk of Court Felipa Anama) explaining the transfer of the case from one division to another. She will also testify as to the circumstances on the docketing of Atty. Estelito Mendoza’s letters as an Administrative Matter (A.M.) case. 20. Felipa Anama, Deputy Clerk of Court of the Supreme Court - corroborating

Clerk of Court Vidal’s testimony, and specifically explaining the Memorandum that she (Anama) prepared explaining the transfer of the case from one division to another. 21. Associate Justices who were present in the October 4, 2011 en banc session (JJ.

Perez, Peralta, Bersamin, Mendoza, Sereno, Reyes, Abad, Villarama, Perlas-Bernabe) - They will testify on the circumstances of the transfer of the FASAP case from one division to another. 22. Bureau of Immigration representative – He/she will produce/testify on the travel

records of respondent Corona in Philippine Airlines (PAL), to show that he accepted special privileges from PAL management while PAL cases are pending before the Supreme Court. 23. Representative employee of the Philippine Airlines (PAL) – He/she will testify on the

travel dates of Renato and Cristina Corona via PAL and the corresponding seats occupied. 24. Representative employee of the Supreme Court handling the official travels of the

Supreme Court Justices – He/she will testify on (1) the official travels of Renato and Cristina Corona via PAL; and (2) classes of tickets purchased by the Supreme Court for these travels whether economy, business or first class. 25. Representative of Prestige Travel Agency – He/she will testify on the official travels

booked by the Supreme Court for Renato and Cristina Corona. 26. Representative of Securities and Exchange Commission (SEC) – He/she will

produce/bring/testify on the SEC records of Prestige Travel Agency to identify its incorporators, directors, stockholders, and officers. Documentary Evidence A. With reference to the testimony of Atty. Gorgonio B. Elarmo Jr

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1.

The original and certified true copy of the Authorization Letter dated 23 November 2010 authorizing Ms. MICHELLE M. MANGUBAT to hold a cash advance in the amount of P100,000.00 to be used to purchase Christmas gifts of the Chief Justice; and

2.

All other requests, authorizations, approvals and such other documents pertaining to cash advances given to Chief Justice Renato C. Corona.

B.

With reference to the testimony of Corazon G. Ferrer-Flores 1. The original and certified true copies of the “MEMORANDUM FOR: HON. RENATO C. CORONA” dated July 16, 2010 on the “Proposed Augmentation of Gasoline Expense Allowance”, and all other memoranda for gas allowances given to the Chief Justice from July 16, 2010 up to the present and such other pertinent documents relating to the preparation, disbursement and liquidation of this item; and 2. Pertinent documents such as but not limited to disbursement vouchers on the gasoline allowances paid to Chief Justice Corona covering the period from June 1, 2010 up to the present.

C.

With reference to the testimony of the Authorized Officer of Shangrila Plaza, EDSA 1. Official Receipt “OR No: 102768 Date: 06/16/2011 As per transaction # 60187 / 422 RECEIVED from Supreme Court” in the amount of P61,740.73 with attached Rustan’s Itemized List consisting of nineteen (19) items; 2. The pertinent Bridal/Gift registry on the 60th Wedding Anniversary of James and Julie Dy, and 3. Other pertinent documents pertaining to this transaction on file with Rustan’s Office.

D.

With reference to the testimony of the Owner/Manager Representative of Design Exchange Incorporated

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1.

Design EXCHANGE Incorporated Sales Invoice No. 4874 dated June 10, 2010 under the name “ c/o CRISTINA CORONA CJ RENATO CORONA” amounting to P20,400; and

2.

Design EXCHANGE Incorporated Sales Invoice No. 4920 dated June 29, 2010 under the name “RENATO CORONA CRISTINA CORONA” amounting to P25,000.

E.

With reference to the testimony of The Corporate Secretary or Assistant Corporate Secretary of JHMC 1. 2. 3. Original Minutes of the Board Meeting of JHMC held on April 3, 2007; Original letter of Executive Secretary Eduardo Ermita dated March 29, 2007; Original desire letter of former President Gloria M. Arroyo dated March 23, 2007, for the election of Mrs. Corona as Chairman and President; 4. 5. Original Letter of Executive Secretary Eduardo Ermita dated July 12, 2007; Original desire letter of PGMA dated July 12, 2007, for election of Mrs. Corona as OIC, Office of the Chairman; 6. 7. Original letter of Executive Secretary Eduardo Ermita dated July 12, 2007; Original desire letter of PGMA dated July 12, 2007, for election of Mrs. Corona as Board Member and President.

F.

With reference to the testimony of Atty. Lyssa GS Pagano Calde 1. 2. Original Position Paper dated May 29, 2007; and Original Position Paper dated June 4, 2007.

G.

With reference to the testimony of Former CA Justice Teodoro P. Regino 1. 2. Original Resolution No. 2007-05-38; Resignation Letter of Teodoro Regino dated June 20, 2007, addressed to PGMA.

14 H. With reference to the testimonies of COA Dir. Ma. Cristina Dizon-Dimagiba, COA Dir. Rosemarie Lacson-Lerio, and COA Suprevising Auditor Atty. Arlyn M. Encarnacion 1. 2. 3. Original Annual Audit Report of JHMC for the year ending December 31, 2007; Original Annual Audit Report of JHMC for the year ending December 31, 2008; Original Annual Audit Report of JHMC for the year ending December 31, 2009; and 4. I. Original Annual Audit Report of JHMC for the year ending December 31, 2010.

With reference to the testimony of the Secretary of the Judicial Bar Council 1. Minutes of JBC Meeting held on April 21, 2010.

J.

With reference to the testimony of Frank Daytec 1. 2. 3. 4. BCC O.R. No. 279937 dated March 14, 2007; BCC O.R. No. 348463 dated March 14, 2010; Disbursement Voucher No. 2010-06-756; and Complaint-Affidavit with Annexes.

K.

With reference to the testimonies of Lauro Vizconde and Dante Jimenez 1. Affidavit of Mr. Lauro Vizconde in compliance with the resolution of the Supreme Court dated January 18, 2011, subscribed and sworn to on 26 January 2011. This document will be presented to show that pursuant to a SC resolution, Mr. Vizconde executed an affidavit wherein he stated that CJ Corona met with him and Dante Jimenez sometime in September 2010 and that CJ divulged information regarding his pending case; 2. Affidavit of Mr. Dante Jimenez in compliance with the resolution of the Supreme Court dated January 18, 2011, subscribed and sworn to on 26 January 2011. This document will be presented to corroborate the statements made in Mr. Vizconde’s affidavit stating that CJ Corona met with him and Lauro Vizconde

15 sometime in September 2010 and that CJ divulged information regarding Mr. Vizconde’s pending case; 3. Supreme Court logbook of visitors from September 1 to September 30, 2010. This document will be presented to show that Mr. Vizconde and Mr. Jimenez was in the Supreme Court for a meeting with CJ Corona; and 4. Resolution of the Supreme Court dated 18 January 2011 directing Mr. Lauro Vizconde and Mr. Dante Jimenez to explain and put on record their explanation regarding remarks they publicly made with respect to the meeting with Chief Justice Corona. This document will be presented to show that the affidavits of Mr. Vizconde and Mr. Jimenez were executed pursuant to a SC resolution. L. With reference to the testimony of Roberto Anduiza 1. Pleadings, decisions, resolutions, notices issued by the Supreme Court relevant to the FASAP case; and 2. M. Letters of FASAP and Atty. Estelito Mendoza.

With reference to the testimony of Atty. Enriqueta Vidal 1. 2. Rollo/Records of FASAP case (G.R. 178083); Memorandum dated September 26, 2011, prepared by her office (through deputy Clerk of Court Felipa Anama) explaining the transfer of the case from one division to another; 3. Logbook of the Raffle Committee showing records of the assignment of the FASAP case; 4. 5. Rollo/Records of A.M. No. 11-10-1-SC; and Agenda and minutes of the en banc session on 4 October 2011.

N.

With reference to the travel records of respondent Corona by PAL

16 1. Travel records/documents of Renato and Cristina Corona from the Bureau of Immigration, Philippine Airlines, and the Supreme Court. 2. 3. Travel bookings of Renato and Cristina Corona through Prestige Travel Agency. SEC records of Prestige Travel Agency to identify its incorporators, directors, stockholders, and officers.

ARTICLE IV
List of Witnesses 1. Court Administrator Jose Midas Marquez - He will testify on the statements

that he made to media on the issuance of the Status Quo Ante Order, especially on his allegation that the justices were given copies of the Petition before the en banc session. 2. Felipa Anama, Deputy Clerk of Court, The Receiving Officer, Receiving Section - They will testify on the process of receipt of petition, pleadings, raffle

of Docket Division, Judicial Records Office, An Officer of the Docket Division and An Officer of the Rollo Room and delivery to the justices and the actual receipt of the Petition in G.R. No. 193459 filed by Merceditas Gutierrez and the subsequent distribution of the copies of the Petition. 3. Johnny Aquino, Process Server of the Supreme Court - He will testify as to

the date and time of delivery of Merceditas Gutierrez’ Petition in G.R. No. 193459 to the Justices and other offices of the Supreme Court, the process of delivery and the route taken and any action taken on Rep. Farinas’ letter dated February 28, 2011, relative to G.R. No. 193459. 4. Antonio Altamia, Attendant, Supreme Court En Banc Room - He will testify as

to whether or not he saw copies of the Petition or the Synopsis in the en banc room before the session at 10:00 a.m. on 14 September 2010. He will also testify on any action taken on Rep. Farinas’ letter dated February 28, 2011, relative to G.R. No. 193459. 5. 193459. Ombudsman Conchita Carpio Morales She will testify on the

circumstances of the issuance of the Status Quo Ante Order in the case docketed as G.R. No.

17 6. Associate Justices who were present at the en banc session on September 14,

2010 (JJ. Carpio, Sereno, Peralta, Abad, Bersamin, Villarama, Del Castillo, Perez, Velasco) They will testify on the circumstances of the issuance of the Status Quo Ante Order in the case docketed as G.R. No. 193459. 7. Clerk of Court Atty. Enriqueta Vidal and Deputy Felipa Anama - They will testify

on the action taken on the letter of Rep. Rudy Farinas dated February 28, 2011, relative to G.R. No. 193459 as well as the Agenda of the Supreme Court in the March 15, 2011 en banc session.

Documentary Evidence A. With reference to the testimony of Court Administrator Jose Midas Marquez 1. Letter of Justice Antonio Carpio to Court Administrator Midas Marquez, dated 4 March 2011; and 2. Press Statement of Justice Maria Lourdes Sereno, dated 9 March 2011, and Corrigendum to Press Statement dated 9 March 2011. With reference to the testimonies of Felipa Anama, The Records Officer, Receiving B. Section of Docket Division, Judicial Records Office, An Officer of the Docket Division and An Officer of the Rollo Room 1. Original Copy of the Petition filed on September 13, 2010 with the stamp “RECEIVED”; 2. 3. 4. C. Rollo/Records of the Merceditas Gutierrez case (G.R. No. 193459); Agenda and minutes of the en banc session of September 14, 2010; and The “Detailed Report”/”Synopsis” of the member-in-charge in G.R. No. 193459.

With reference to the testimony of Johnny Aquino 1. 2. Delivery receipt/logbook used by Johnny Aquino; and Logbooks of the Justices showing receipt of Petition (dates: September 13, 14, 15, 2010).

D.

With reference to the testimonies of Atty. Enriquetta Vidal and Deputy Felipa Anama 1. Letter of Rep. Rudy Farinas dates February 28, 2011;

18 2. Any document/affidavit that was prepared in connection with the letter of Rep. Farinas; 3. 4. Official answer to Rep. Farinas’ letter dated March 15, 2011; and Agenda and minutes of March 15, 2011 en banc session.

ARTICLE V
List of Witnesses 1. Atty. Enriqueta Vidal, Clerk of Court, Supreme Court – She will testify with respect to the

League of Cities vs. COMELEC case to: (1) prove date of the finality of the pertinent decisions and resolutions and the entry in the book of judgments; (2) identify the letters of Atty. Estelito Mendoza to the Supreme Court and testify on the contents thereof; (3) prove that respondent Corona was aware of and had knowledge of the letters, whether actually or constructively, pursuant to the internal procedures of the Supreme Court; and (4) testify on the internal procedures of the Supreme Court to show that respondent Corona had the power to include the League of Cities case in the agenda of the En Banc. With respect to the Navarro vs. Ermita case, Atty. Vidal will prove the date of finality of the pertinent decisions and the date the same were entered in the Book of Judgments, and testify on the internal rules of the Supreme Court to show that respondent Corona had caused the inclusion of the case in the agenda of the Supreme Court En Banc in order that a final and executory judgment will be reversed. Lastly, as to the FASAP vs. Philippine Airlines, Inc., she will testify: (1) to prove the date of finality of the pertinent decisions and resolutions; (2) to identify the letters of Atty. Estelito Mendoza; (3) to prove that Corona was aware of and had knowledge of the contents of said letter, whether actually or constructively, pursuant to the internal procedures of the Supreme Court; (4) on the Internal Rules of the Supreme Court (A.M. 99-8-09-SC); (5) to prove whether under the Internal Rules of the Supreme Court, the Supreme Court en banc can revisit or recall decisions that have become final; (6) to prove the role of the Chief Justice in setting matters in the agenda for the Supreme Court en banc; (7) to authenticate and testify on the contents of A.M. No. 11-10-1-SC and the Memorandum dated 26 September 2011 on the propriety of the raffle of the FASAP Case; (8) to testify that the said memorandum was issued in response to the letters of Atty. Estelito Mendoza; (9) to testify that as Presiding Officer of the Supreme Court, Corona caused the inclusion of the FASAP case in the agenda of the En Banc; (10) to testify on

19 Corona’s participation in A.M. No. 11-10-1-SC; (11) to testify on the Raffle results of 14 July 2008 relative to the FASAP Case, which indicate that Corona had previously inhibited himself from the case; and (12) to testify on the relevant facts which caused the setting aside of decisions which were already final and executory. 2. Representative of the League of Cities – who will testify, among others: (1) on the

background of the case; (2) that they did not receive copies of the letter of Mendoza prior to the issuance by the Supreme Court of the Resolution dated 15 February 2011; and (3) that the League of Cities was not required to comment on the letters before the Supreme Court acted on the same. 3. A former Justice of the Supreme Court or other legal expert – who will testify on the

following: rules on finality of judgment, propriety of transmitting private letters to the Supreme Court and the internal procedures of the Supreme Court pursuant to which respondent Corona had the power to include the League of Cities case in the agenda of the En Banc. 4. A former Justice of the Supreme Court or other legal expert – who will testify on the

rules on finality of judgment and the internal procedures of the Supreme Court pursuant to which respondent Corona had included the Navarro Case in the agenda of the En Banc. 5. A Former Justice of the Supreme Court or other legal expert – who will testify on the

rules on finality of judgment, rules on Motions for Reconsideration, the propriety of transmitting private letters to the Supreme Court and the internal procedures of the Supreme Court pursuant to which Corona included the FASAP case in the agenda of the En Banc. 6. and divisions Responsible officials, employees, and staff of the Supreme Court and its departments – who are privy to the proceedings and deliberations in the League of Cities Case, Navarro

Case, and FASAP case. 7. Assistant Clerk of Court Felipa Anaman – who will, among others, (1) testify that she

prepared a memo on the raffle of the FASAP case to the Second Division; (2) authenticate and testify on the contents of the Legal Memorandum; (3) testify on the Internal Rules of the Supreme Court (A.M. 99-8-09-SC); (4) prove whether under the Internal Rules of the Supreme Court, the Supreme Court en banc can revisit or recall decisions that have become final; (5) prove the role of the Chief Justice in setting matters in the agenda for the Supreme Court en banc; and (6) authenticate and testify on the contents of A.M. No. 11-10-1-SC. 8. Representative of FASAP – who will testify, among others: (1) about the background of

the case; (2) that FASAP wrote to the Supreme Court to inquire on the status and the Supreme Court

20 action on the matter; (3) that FASAP was required by the Supreme Court to furnish a copy of its letter to the other parties; (4) that FASAP did not receive copies of the letters filed by Atty. Estelito Mendoza prior to the Decision in AM No. 11-10-1-SC; and (5) that FASAP was not asked to comment on the said letters before the Supreme Court acted on the same.

Documentary Evidence A. With reference to the League of Cities Case 1. Personal Letter sent by Estelito Mendoza to the Supreme Court on 19 January 2009 - To prove that the letter was instrumental in the flip-flopping of the Supreme Court in League of Cities v. COMELEC. 2. Certified True Copy of the Decision dated 18 November 2008 in League of Cities v. COMELEC - To prove the fact and date the Decision dated 18 November 2008 was promulgated. 3. Entry of judgment of the Decision dated 18 November 2008 in League of Cities v. COMELEC - To prove that the Decision dated 18 November 2008 has become final and executory. 4. Certified True Copy of the Decision dated 21 December 2009 in League of Cities v. COMELEC - To prove the improper reversal of the final and executory Decision dated 18 November 2008. 5. Certified True Copy of the Resolution dated 24 August 2010 in League of Cities v. COMELEC - To show that members of the Supreme Court En Banc realized the blatant error in the previous ruling, thus, reinstating the original Decision dated 18 November 2008. 5. Certified True Copy of the Resolution dated 15 February 2011 in League of Cities v. COMELEC - To prove that the Supreme Court granted an unusual and totally unprecedented fourth motion for reconsideration filed by the sixteen (16) municipalities and improperly reinstated the Decision dated 21 December 2009, the highly irregular decision reversing a judgment that had long been final and executory, and to prove that respondent Corona participated therein.

21 B. With reference to the Navarro Case 1. Decision dated 10 February 2010 in Navarro v. Ermita - To prove the fact and date the Decision was promulgated. 2. Entry of Judgment dated 18 May 2010 in Navarro v. Ermita - To prove the fact that the Decision dated 10 February 2010 has become final and executory. 3. Resolution dated 20 July 2010 in Navarro v. Ermita - To show the proper

application of the rules on intervention wherein the Supreme Court held that when the case has already been terminated, intervention cannot be allowed. 4. Resolution dated 12 April 2011 in Navarro v. Ermita - To prove that under

respondent Corona's leadership, the Supreme Court directly violated the Rules of Court, the rules on reconsideration, finality of judgments and intervention. 5. Sworn statements of responsible Supreme Court officials, employees, and staff privy to the proceedings and deliberations in Navarro v. Ermita and issue reversals in the forgoing cases C. With reference to the FASAP Case 1. Decision dated 22 July 2008 in FASAP v. Philippine Airlines, Inc., et al - To prove the fact and date the Decision was promulgated. 2. Resolutions of the Supreme Court dated 02 October 2009 and 07 September 2011. - To prove that the Decision dated 22 July 2008 became final after the Supreme Court denied, with finality, PAL’s Motions for Reconsideration. 3. Personal letter submitted to the Supreme Court by Estelito Mendoza, PAL’s lawyer, dated 13 and 20 September 2011 October 2009 and 07 September 2011. 4. A.M. No. 11-10-1-SC - To show the improper recall of the Resolutions dated 02 October 2009 and 07 September 2011 by virtue of a decision in a separate case decided by the Supreme Court on 04 October 2011, and the participation of Corona therein. - To show that the letter from Estelito Mendoza is instrumental in the later recall of the Resolutions dated 02 - To prove respondent Corona’s direct acts and involvement in disregarding the finality of judgments

22

5.

Memorandum written by the Clerk of Court of the Supreme Court En Banc dated 26 September 2011 - To show that the current assignment for the FASAP Case to the Second Division was proper under the rules of the Supreme Court, which did not justify Corona’s action in moving to recall the final and executory decision of 22 July 2008.

6.

Raffle Results on 14 July 2008 himself from the FASAP Case.

- To show that Corona had initially inhibited

7.

Minutes of the Raffle Committee of 11 November 2009, a list of members thereof and Raffle Results on 11 November 2009 - To show that Corona was a member of the Raffle Committee that had decided that a Special Division need not be created for the resolution of the Motion for Reconsideration in the FASAP Case.

8.

All memoranda/correspondence to and from the Clerk of Court of the Supreme Court En Banc regarding the FASAP Case decision in A.M. No. 11-10-1-SC. - To establish facts surrounding the

9.

FASAP Letter to the Supreme Court inquiring about the status of their case, and the Supreme Court’s communication to FASAP requiring FASAP to first furnish the opposing party with a copy of their letters before it would act on the inquiries - To show impartiality and bias in favor of Atty. Estelito Mendoza.

10.

Sworn statements of responsible Supreme Court officials, employees, and staff privy to the proceedings and deliberations in Flight Attendants and Stewards Association of the Philippines (FASAP) v. Philippine Airlines, Inc., et al. - To prove respondent Corona’s direct acts and involvement in influencing the other Members of the Supreme Court En Banc to disregard the finality of judgments and issue reversals in the forgoing cases.

ARTICLE VI
List of Witnesses 1. Atty. Harry Roque - He will bring, present, identify, and testify on the original

copies of the books, articles, journals, and materials that were plagiarized and misrepresented

23 in the case of Isabelita C. Vinuya versus the Honorable Executive Secretary Alberto G. Romulo docketed as G.R. No. 162230 and the original and certified true copy of the impeachment complaint filed against Associate Justice del Castillo. 2. Atty. Emmanuel M. Lombos - He will demonstrate the impossibility that a mere

computer glitch caused the deletion of the footnotes in the Decision dated April 28, 2010 in Isabelita C. Vinuya versus the Honorable Executive Secretary Alberto G. Romulo docketed as G.R. No. 162230. 3. Atty. Nelson T. Antolin - He will demonstrate the impossibility that a mere

computer glitch caused the deletion of the footnotes in the Decision dated April 28, 2010 in Isabelita C. Vinuya versus the Honorable Executive Secretary Alberto G. Romulo docketed as G.R. No. 162230. 4. Atty. Michelle Ann U. Juan - She will bring, present, identify, and testify on the

written explanation she submitted to the Ethics Committee narrating the extent of her participation and how the deletions/absence of attributions of authorities cited in the draft of the Decision of the Supreme Court dated April 28, 2010 in Isabelita C. Vinuya versus the Honorable Executive Secretary Alberto G. Romulo docketed as G.R. No. 1622300. 5. Atty. Cynthia del Castillo - She will testify that Chief Justice Corona was the best

man at the wedding of Associate Justice del Castillo. 6. Atty. Enriqueta Esguerra-Vidal - She will testify on the proceedings

involving the Vinuya vs. Executive Secretary case and on all proceedings of the Supreme Court relating to AM No. 10-7-17-SC, including the proceedings of the Ethics Committee. In the course of his direct examination, he/she will identify documents. Documentary Evidence A. With reference to the testimony of Atty. Enriqueta Esguerra-Vidal Decision dated April 28, 2010 in Isabelita C. Vinuya versus the Honorable Executive Secretary Alberto G. Romulo docketed as G.R. No. 162230, including the concurring and dissenting opinions of the other justices, if there are any;
2.

1.

The Motion for Reconsideration filed by the petitioners in Isabelita C. Vinuya versus the Honorable Executive Secretary Alberto G. Romulo docketed as G.R.

24 No. 162230;
3.

The Supplemental Motion for Reconsideration filed by the petitioners in Isabelita C. Vinuya versus the Honorable Executive Secretary Alberto G. Romulo docketed as G.R. No. 162230;

4.

The Resolution on the Motion for Reconsideration and the Supplemental Motion for Reconsideration (described in b and c above), including all the concurring and dissenting opinions of the other justices, if there are any;

5.

The Resolution of the Supreme Court creating the Ethics Committee, showing the jurisdiction of such Committee;

6.

Resolution activating the Ethics Committee to investigate Associate Justice del Castillo in connection with A.M. No. 10-7-17-SC;

7.

The Resolution/Findings/Recommendation of the Ethics Committee in A.M. No. 10-7-17-SC;

8.

The Resolution of the Supreme Court dated October 12, 2010 in A.M. No. 10-717-SC, including all the concurring and dissenting opinions of the other justices, if there are any;

9.

The Resolution of the Supreme Court dated February 8, 2011 in A.M. No. 10-717-SC; and

10.

An inventory of administrative complainants filed against justices of the Supreme Court, the number of those complaints referred to the Ethics Committee for investigation, the corresponding findings/resolution/ recommendation of the Ethics Committee, and the corresponding decision/resolution of the Supreme Court on findings/resolution/recommendation of the Ethics Committee.

ARTICLE VII
List of Witnesses 1. Ms. Raissa Robles - She who will testify on, among others, the close personal

relationship between Corona and GMA and other allegations contained in the Verified

25 Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. 2. Ms. Marites Vitug - She will testify among others on the close personal

relationship between Corona and GMA, the research she has on the Supreme Court inner processes and other allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. 3. Justice Secretary Leila de Lima - She will testify, among others: (1) That various

criminal cases have been filed against GMA and FG; (2) That GMA intends to travel for other reasons aside from health (3) That service of the TRO to the Department of Justice was attempted to be made before 6 p.m. on 15 November 2011; (4) That petitioners GMA and FG attempted to escape the country on November 15, 2011; (5) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. 4. Principal Physician of former President Gloria Macapagal- Arroyo, Dr. Juliet

Gopez-Cervantes - who will attest to GMA’s continuing recovery and her positive prognosis, especially after 6 to 8 months and that there is no medical emergency warranting an immediate flight. 5. Dr. Mario Ver – who will attest to GMA’s continuing recovery and her positive

prognosis, especially after 6 to 8 months and that there is no medical emergency warranting an immediate flight. 6. Supreme Court Process Cashier – who will testify, among others: (1) On the

working hours of the Supreme Court; (2) that the conditions set on the TRO were submitted beyond working hours. 7. Ms. Ina Reformina and her cameraman – She will testify, among others: (1) That

the TRO allowing GMA to leave the country was issued before 6 p.m. on 15 November 2011; (2) That service of the TRO to the Department of Justice was attempted to be made before 6 p.m. on 15 November 2011; (3) That Compliance with TRO requirements, such as the posting of the bond, among others, was made after 6 p.m. on 15 November 2011; (4) Statements made by the Public Information Office of the Supreme Court related to the TRO; (5) will testify that SC spokesperson Midas Marquez announced to media (through press conference) the 8-5 ruling in favor of a TRO against Arroyo's WLO, though said resolution was still being drafted; (6) manner

26 of compliance on the conditions set in the TRO , including the manner of securing payment of bond; statements made by lawyers of GMA and FG on the flight bookings and payment of bond; (7) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. 8. Ms. Lia Manalac and her cameraman – She will testify, among others: (1) That

the TRO allowing GMA to leave the country was issued before 6 p.m. on 15 November 2011; (2) That service of the TRO to the Department of Justice was attempted to be made before 6 p.m. on 15 November 2011; (3) That Compliance with TRO requirements, such as the posting of the bond, among others, was made after 6 p.m. on 15 November 2011; (4) Statements made by the Public Information Office of the Supreme Court; (5) will testify that SC spokesperson Midas Marquez announced to media (through press conference) the 8-5 ruling in favor of a TRO against Arroyo's WLO, though said resolution was still being drafted; 6) manner of compliance on the conditions set in the TRO related to the TRO, including the manner of securing payment of bond; statements made by lawyers of GMA and FG on the flight bookings and payment of bond; (7)On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. 9. Marlon Ramos-Inquirer - He will testify, among others: (1) That the TRO allowing

GMA to leave the country was issued before 6 p.m. on 15 November 2011; (2) That service of the TRO to the Department of Justice was attempted to be made before 6 p.m. on 15 November 2011; (3) That Compliance with TRO requirements, such as the posting of the bond, among others, was made after 6 p.m. on 15 November 2011; (4) Statements made by the Public Information Office of the Supreme Court related to the TRO; (5) will testify that SC spokesperson Midas Marquez announced to media (through press conference) the 8-5 ruling in favor of a TRO against Arroyo's WLO, though said resolution was still being drafted; (6) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. 10. Zen Hernandez and her cameraman-ABS-CBN - He will testify, among others:

(1) That the TRO allowing GMA to leave the country was issued before 6 p.m. on 15 November 2011; (2) That service of the TRO to the Department of Justice was attempted to be made before 6 p.m. on 15 November 2011; (3) That Compliance with TRO requirements, such as the posting of the bond, among others, was made after 6 p.m. on 15 November 2011; (4) Statements made by the Public Information Office of the Supreme Court related to the TRO; (5) will testify that SC spokesperson Midas Marquez announced to media (through press

27 conference) the 8-5 ruling in favor of a TRO against Arroyo's WLO, though said resolution was still being drafted; (6) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. 11. Mark Meruenas, GMA News – He will testify that Midas Marquez said that the

TRO is immediately executory and that it should be respected by DOJ (threat of contempt). He will also testify that Marquez said that TRO conditions should be complied with first. He quotes Marquez: "Upon filing these conditions or once they are able to comply with these conditions, they can fly already.” 12. Deputy Clerk of Court- She will testify, among others: (1) That respondent

Corona consolidated the two (2) cases involving Arroyo and her husband Mike in order to ensure the hurried issuance of the TRO against the DOJ on 15 November 2011; (2) That the hurried issuance of the TRO against the DOJ on 15 November 2011 by respondent Corona was made in order to give the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice; (3) That such issuance is a tyrannical abuse of power, an act of favoritism and an inexcusably negligent act amounting to a betrayal of public trust; (4) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. 13. Atty. Enriqueta Vidal, Clerk of Court of the Supreme Court En Banc – She will

testify, among others: (1) that Respondent Corona made handwritten corrections on the typewritten draft Resolution Justice Velasco with the instruction that the Chief Justice’s version is to be immediately promulgated; (2) Suppress the dissent of Justice Sereno; (3) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case; (4) That respondent Corona consolidated the two (5) cases involving Arroyo and her husband Mike in order to ensure the hurried issuance of the TRO against the DOJ on 15 November 2011; (6) That the hurried issuance of the TRO against the DOJ on 15 November 2011 by respondent Corona was made in order to give the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice; (7) That such issuance is a tyrannical abuse of power, an act of favoritism and an inexcusably negligent act amounting to a betrayal of public trust; (8) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. 14. Benjamin Anunuevo and/or the Assigned Process Server or Sheriff who served

the TRO – He will testify, among others: (1) That respondent Corona in order to immediately

28 effect the TRO extended the office hours, asked him to do overtime and to immediately serve the Notices to the Department of Justice and the Office of the Solicitor General; 15. Ms. Araceli C. Bayuga, SC Chief Judicial Officer and/or the Cashier assigned on

15 November 2011 at the Supreme Court - She will testify, among others: (1) that respondent Corona in order to immediately effect the TRO extended the office hours, asked them to facilitate the payment of the bond to ensure compliance; (2) the time and manner of payment (3) the time that they informed the Office of the Clerk of Court of the payment of the bond. 16. “Juliet” of the Office of the Clerk of Court – She will testify that it was only at

8:55am of November 16, one day after GMA attempted to leave, that they received information of the payment of the Bond. 17. Mr. Jay Francis P. Baltazar, Notary Public of Magallanes, Makati City - He will

testify as to the time and manner that the Special Power of Attorney made in favor of Gloria Macapagal Arroyo was notarized.

18.

Justice Maria Lourdes Sereno – She will testify, among others: (1) That the

hurried issuance of the TRO against the DOJ on 15 November 2011 by respondent Corona in order to give the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice is a tyrannical abuse of power, an act of favoritism and an inexcusably negligent act amounting to a betrayal of public trust. This was made possible through respondent’s individual acts of: (i) Consolidating the two (2) cases involving Arroyo and her husband Mike; (ii) Facilitating and expediting, as administrative head of the Supreme Court, the issuance and implementation of the TRO issued in favor of Arroyo (i.e. allowing the extension of the office hours of the Supreme Court, among others); (iii) Distorting the Supreme Court decision on the effectivity of the TRO in view of a clear failure to comply with the conditions of the Supreme Court amounted to a betrayal of public trust; (iv) Suppressing the promulgation of the dissenting opinion of Justice Sereno which was submitted on 2 December 2011 but was promulgated only on 13 December 2011; and (v) Providing the Supreme Court spokesman with misleading information; and (2) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. 19. Court Administrator Jose Midas P Marquez – He will testify, among others on

his statements made in relation to the TRO against the DOJ. He will also testify on the issuance of the TRO against the DOJ on 15 November 2011 by respondent Corona in order to give the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice. He will also

29 talk on the following acts by Respondent: (i) Consolidating the two (2) cases involving Arroyo and her husband Mike; (ii) Facilitating and expediting, as administrative head of the Supreme Court, the issuance and implementation of the TRO issued in favor of Arroyo (i.e. allowing the extension of the office hours of the Supreme Court, among others); (iii) Distorting the Supreme Court decision on the effectivity of the TRO in view of a clear failure to comply with the conditions of the Supreme Court amounted to a betrayal of public trust; (iv) Suppressing the promulgation of the dissenting opinion of Justice Sereno which was submitted on 2 December 2011 but was promulgated only on 13 December 2011; and (v) Providing the Supreme Court spokesman with misleading information; (2) that Respondent Corona made handwritten corrections on the typewritten draft Resolution Justice Velasco with the instruction that the Chief Justice’s version is to be immediately promulgated; and (3) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. (2) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. 20. Justice Antonio T. Carpio – He will testify, among others: (1) That the hurried

issuance of the TRO against the DOJ on 15 November 2011 by respondent Corona in order to give the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice is a tyrannical abuse of power, an act of favoritism and an inexcusably negligent act amounting to a betrayal of public trust. This was made possible through respondent’s individual acts of: (i) Consolidating the two (2) cases involving Arroyo and her husband Mike; (ii) Facilitating and expediting, as administrative head of the Supreme Court, the issuance and implementation of the TRO issued in favor of Arroyo (i.e. allowing the extension of the office hours of the Supreme Court, among others); (iii) Distorting the Supreme Court decision on the effectivity of the TRO in view of a clear failure to comply with the conditions of the Supreme Court amounted to a betrayal of public trust; (iv) Suppressing the promulgation of the dissenting opinion of Justice Sereno which was submitted on 2 December 2011 but was promulgated only on 13 December 2011; and (v) Providing the Supreme Court spokesman with misleading information; (2) that Respondent Corona made handwritten corrections on the typewritten draft Resolution Justice Velasco with the instruction that the Chief Justice’s version is to be immediately promulgated; and (3) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. (2) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case.

30 21. Justice Bienvenido Reyes – He will testify, among others: (1) That the hurried

issuance of the TRO against the DOJ on 15 November 2011 by respondent Corona in order to give the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice is a tyrannical abuse of power, an act of favoritism and an inexcusably negligent act amounting to a betrayal of public trust. This was made possible through respondent’s individual acts of: (i) Consolidating the two (2) cases involving Arroyo and her husband Mike; (ii) Facilitating and expediting, as administrative head of the Supreme Court, the issuance and implementation of the TRO issued in favor of Arroyo (i.e. allowing the extension of the office hours of the Supreme Court, among others); (iii) Distorting the Supreme Court decision on the effectivity of the TRO in view of a clear failure to comply with the conditions of the Supreme Court amounted to a betrayal of public trust; (iv) Suppressing the promulgation of the dissenting opinion of Justice Sereno which was submitted on 2 December 2011 but was promulgated only on 13 December 2011; and (v) Providing the Supreme Court spokesman with misleading information; (2) that Respondent Corona made handwritten corrections on the typewritten draft Resolution Justice Velasco with the instruction that the Chief Justice’s version is to be immediately promulgated; and (3) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. (2) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. 22. Justice Arturo D. Brion – He will testify, among others: (1) That the hurried

issuance of the TRO against the DOJ on 15 November 2011 by respondent Corona in order to give the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice is a tyrannical abuse of power, an act of favoritism and an inexcusably negligent act amounting to a betrayal of public trust. This was made possible through respondent’s individual acts of: (i) Consolidating the two (2) cases involving Arroyo and her husband Mike; (ii) Facilitating and expediting, as administrative head of the Supreme Court, the issuance and implementation of the TRO issued in favor of Arroyo (i.e. allowing the extension of the office hours of the Supreme Court, among others); (iii) Distorting the Supreme Court decision on the effectivity of the TRO in view of a clear failure to comply with the conditions of the Supreme Court amounted to a betrayal of public trust; (iv) Suppressing the promulgation of the dissenting opinion of Justice Sereno which was submitted on 2 December 2011 but was promulgated only on 13 December 2011; and (v) Providing the Supreme Court spokesman with misleading information; (2) that Respondent Corona made handwritten corrections on the typewritten draft Resolution Justice Velasco with the instruction that the Chief Justice’s version is to be immediately promulgated; and (3) On the allegations contained in the Verified Complaint, and other pleadings filed by

31 complainants, and other matters relevant to the instant case. (2) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. 23. Justice Presbitero J. Velasco, Jr. – He will testify, among others: (1) That the

hurried issuance of the TRO against the DOJ on 15 November 2011 by respondent Corona in order to give the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice is a tyrannical abuse of power, an act of favoritism and an inexcusably negligent act amounting to a betrayal of public trust. This was made possible through respondent’s individual acts of: (i) Consolidating the two (2) cases involving Arroyo and her husband Mike; (ii) Facilitating and expediting, as administrative head of the Supreme Court, the issuance and implementation of the TRO issued in favor of Arroyo (i.e. allowing the extension of the office hours of the Supreme Court, among others); (iii) Distorting the Supreme Court decision on the effectivity of the TRO in view of a clear failure to comply with the conditions of the Supreme Court amounted to a betrayal of public trust; (iv) Suppressing the promulgation of the dissenting opinion of Justice Sereno which was submitted on 2 December 2011 but was promulgated only on 13 December 2011; and (v) Providing the Supreme Court spokesman with misleading information; (2) that Respondent Corona made handwritten corrections on the typewritten draft Resolution Justice Velasco with the instruction that the Chief Justice’s version is to be immediately promulgated; and (3) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. (2) On the allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case. 24. Other Supreme Court Officials and media personnel who may be determined

as the custodians of the documents that will be identified and authenticated.

Documentary Evidence 1. Supreme Court-received (with time and date stamp) Petition for Special Civil Actions for Certiorari and Prohibition with Prayer for the Issuance of a Temporary Restraining Order (TRO) and/or Writ of Preliminary Injunction filed by Gloria Macapagal Arroyo (G.R. No. 199034) [GMA TRO Petition], including the Annexes thereto;

32 2. Supreme Court received (with time and date stamp) Petition for Special Civil Actions for Certiorari and Prohibition with Prayer for the Issuance of a Temporary Restraining Order and/or Writ of Preliminary Injunction docketed as (G.R. No. 199046) [Mike Arroyo TRO Petition], including the Annexes thereto; 3. Official Leave of Respondent Corona applied for days within the month of November 2011; 4. Minutes of the Supreme Court Raffle Committee which handled the GMA and Mike Arroyo TRO Petition; 5. Appointment or Assignment of the Member in Charge of the GMA and Mike Arroyo TRO Petition; 6. Agenda and Minutes of the Supreme Court En Banc Sessions dated 15 November 2011; 7. Resolution dated 15 November 2011 on the GMA and Mike Arroyo TRO Petition, as published; 8. Temporary Restraining Order dated 15 November 2011 issued in the GMA and Mike Arroyo TRO Petition; 9. Special Power of Attorney dated 15 November 2011 submitted by GMA and Mike Arroyo in favor of Atty. Ferdinand Topacio appointing him “to produce summons or receive documentary evidence” with the official date and time stamp of the Supreme Court; 10. Official Receipt No. 00300227-SC-EP dated 15 November 2011 issued by the Supreme Court for the Two Million Pesos Cash Bond of GMA and Mike Arroyo with the official date and time stamp; 11. November 15 and 16, 2011 Sheriff’s Return of service of the GMA and Mike Arroyo TRO dated 15 November 2011 upon the Department of Justice and the Office of the Solicitor General;

33 12. Certification from the Fiscal Management and Budget Office of the Supreme Court dated November 15, 2011 with the date and time it was received by the Supreme Court Clerk of Court showing it to be November 16, 2011 at 8:55am; 13. Agenda and Minutes of the Supreme Court En Banc Sessions dated 18 November 2011; 14. Resolution dated 18 November 2011 issued on the GMA and Mike Arroyo TRO Petition, as published; 15. Agenda and Minutes of the Supreme Court En Banc Sessions dated 22 November 2011; 16. Typed-written draft of Justice Presbitero Velasco (Justice Velasco) of the 22 November 2011 session on the GMA and Mike Arroyo TRO Petition (Justice Velasco draft); 17. Justice Antonio T. Carpio’s Modifications of Justice Velasco’s draft on the GMA and Mike Arroyo TRO Petition; 18. Respondent Corona’s handwritten corrections on Justice Velasco’s draft on the GMA and Mike Arroyo TRO Petition dated 22 November 2011 with the instruction that the Chief Justice’s version is to be immediately promulgated as received by the Supreme Court Clerk of Court on 23 November 2011; 19. Resolution dated 22 November 2011 on the GMA and Mike Arroyo TRO Petition, as published; 20. Logbook showing the date and time Justice Sereno’s dissent to the 22 November 2011 Resolution was received by the Clerk of Court En Banc; 21. Dissenting Opinion of Justice Sereno in G.R. No. 199034 and 199046 as published on 13 December 2011; 22. Dissenting Opinion of Justice Carpio in G.R. No. 199034 and 199046 as published;

34 23. Agenda and Minutes of the Supreme Court En Banc Sessions dated 24 November 2011; 24. Agenda and Minutes of the Supreme Court En Banc Sessions dated 29 November 2011 25. Dissenting Opinion of Justice Velasco in G.R. No. 199034 and 199046 as published; 26. 27. Dissenting Opinion of Justice Abad in G.R. No. 199034 and 199046 as published; Letter dated 24 November 2011 of Justice Carpio addressed to the Chief Justice with title: “Re: GR No. 199034, Gloria Macapagal Arroyo v. Hon. Leila M. De Lima” copy furnished to all Justices and the Clerk of Court. 28. Memorandum dated 05 December 2011 of Clerk of Court Enriqueta E. Vidal for the Chief Justice and the Associate Justices stating that as “per instruction of Associate Justice Presbitero J. Velasco, the dissenting opinion of Associate Justice Maria Lourdes P.A. Sereno (Sereno) in the Resolution dated 22 November 2011 shall be taken up in the session of the En Banc on Tuesday, December 6, 2011”; 29. Letter dated 06 December 2011 of Justice Sereno to respondent Corona formalizing her request to be apprised of the legal basis for the nonpromulgation of her dissenting opinion, unduly depriving her of her constitutional right as an associate justice copy, furnished to all Justices and the Clerk of Court; 30. Agenda and Minutes of the Supreme Court En Banc Sessions dated 06 December 2011; 31. Certified True Copy of the decision in “Leave Division OCA-OAS vs. Wilma Salvacion P. Huesdens” docketed as A.M. No. P-11-2927, promulgated on 13 December 2011; 32. Certified True Copy of the Supreme Court Internal Rules;

35 33. Certified True Copy of G.R. No. 197930 where the Supreme Court denied Efraim Genuino’s prayer for a TRO against Watchlist Order No. 2011-422, issued under the authority of the same DOJ Circular No. 41 that is the subject of the GMA and Mike Arroyo TRO Petitions; 34. Official Appointment of Respondent Corona as Associate Justice of the Supreme Court; 35. 36. Official Appointment of Respondent Corona as Chief Justice; Official Appointment of Midas Marquez as Spokesperson of the Supreme Court. As stated in the Complaint, the Spokesperson in several instances made misleading statements; 37. Official Appointment of Justice Arturo D. Brion (Brion) as Justice of the Supreme Court. Justice Brion was present in the meetings and may shed light as to who drafted the Resolutions dated November 15 and November 18 2011 on the GMA and Mike Arroyo TRO Petition; 38. Official Appointment of Justice Presibetero Velasco as Justice of the Supreme Court. Justice Velasco was mentioned several times in the Dissenting Opinion of Justice Sereno in G.R. No. 199034 and 199046 as published and he filed a Dissenting Opinion in G.R. No. 199034 and 199046 as published; 39. Official Appointment of Justice Roberto A. Abad as Justice of the Supreme Court. Justice Abad filed a Dissenting Opinion in G.R. No. 199034 and 199046 as published 40. Bureau of Immigration Records stating the entry and exit in the Philippines of Respondent Renato Corona during the months of October and November, 2011; 41. Department of Justice received Petition for Special Civil Actions for Certiorari and Prohibition with Prayer for the Issuance of a Temporary Restraining Order (TRO) and/or Writ of Preliminary Injunction filed by Gloria Macapagal Arroyo (G.R. No. 199034) [GMA TRO Petition], including the Annexes thereto;

36 42. Department of Justice received Supreme Court received (with time and date stamp) Petition for Special Civil Actions for Certiorari and Prohibition with Prayer for the Issuance of a Temporary Restraining Order and/or Writ of Preliminary Injunction docketed as (G.R. No. 199046) [Mike Arroyo TRO Petition], including the Annexes thereto; 43. All pleadings and motions filed and received in the Mike Arroyo and GMA TRO Petition; 44. Record of Denial of the Attempted Exit of Gloria Macapagal Arroyo (GMA) and Jose Miguel Tuason Arroyo (Mike Arroyo) with the Bureau of Immigration on November 15, 2011; 45. Warrants of Arrest issued by Branch 112 of the Regional Trial Court of Pasay City against GMA; 46. Department of Justice received Special Power of Attorney dated 15 November 2011 submitted by the Arroyos in favor of Atty. Ferdinand Topacio appointing him “to produce summons or receive documentary evidence.”; 47. Department of Justice received Manifestation or Motion informing them of the Compliance with the conditions set in the 15 November 2011 TRO issued by the Supreme Court in the GMA and Mike Arroyo TRO Petition; 48. Department of Justice Resolutions on the cases filed against Gloria Macapagal Arroyo and First Gentleman Mike Arroyo; 49. 50. 51. News Videos showing the implementation of the TRO; Doctor Certificate showing the diagnosis of GMA; Videos showing the statements of Midas Marquez related to the issuance of the TRO, including the one made between 1:00 to 2:00 pm, 15 November 2011 where Marquez announced to the media the TRO against Arroyo's WLO, though said resolution was still being drafted. He is reported to have said that. "Upon

37 filing these conditions or once they are able to comply with these conditions, they can fly already,"

ARTICLE VIII
List of Witnesses 1. Ms. Lourdes Lim, COA Supervising Auditor to the Supreme Court - She will

testify on the result of her audit report – Annual Audit Report (AAR) of the Supreme Court of the Philippines for CY 1009 and 2010, their findings and recommendations contained in their AAR’s and that Respondent Chief Justice asked COA not to publish the AAR’s in the COA website. 2. Ms. Myrna Cells, COA Auditor to the Supreme Court - She will testify that she

was part of the team headed by Lourdes Lim who conducted an audit on the accounts and financial operations of the SC for CY 2009 and 2010; their findings and recommendations as contained in the AAR for CY 2009 and 2010; and other relevant matters contained in the AAR. 2. Department of Budget and Management (or Civil Service Commission) Records

Custodian – He/She will testify on the submission of the Personal Services Itemization and Plantilla of Personnel (PSIPOP) as submitted to their office (DBM) by the SC as well as the budget allocated for it. 3. Ms. Lilianne E. Ulgado, SC’s Chief Accountant - She will testify, among

others, on the contents of the Supreme Court’s Financial Statements; that funds allocated for Personal Services, MOOE in the SCP’s General Funds for CY 2010 and funds allocated for Personal Services and MOOE for PET for CY 2010, while declared in the Financial Statements to have been fully utilized, were transferred to the Fiscal Autonomy Fund of the Supreme Court. She will likewise testify that such transfers were personally and directly authorized by the Respondent Chief Justice.

4.

Ms. Corazon G. Ferrer-Flores, Chief of SC’s Fiscal Management and Budget

Office (FMBO) - She will testify as to the declaration of the Management’s Responsibility for Financial Statements of SC and its significance and to corroborate the testimony of Ms. Ulgado.

38 5. COA Auditor for the Fiscal Autonomy Fund (CFAG Fund) - She will testify to

corroborate the testimony of Ms. Ulgado; that in the performance of her duties and responsibilities, she conducted and audit on the SC’s CFAG Fund; Her audit findings on the SC’s CFAG Funds. 6. Representative of the World Bank’s Judicial Reform Support Project –who will testify, among

others, on: (1) the authenticity and contents of the Report of the World Bank Implementation Support Mission for the JRSP; (2) the various questionable expenditures incurred by respondent Corona, which are indicia of the commission of graft and corruption; (3) that certain disallowed expenditures had to be reimbursed by the Supreme Court; (4) the uncertain future of the JRSP in the Philippines due to the questionable expenditures authorized by respondent Corona; and (5) other matters relevant to the instantcase.

Documentary Evidence A. With reference to the testimonies of Lourdes Lim and Myrna Cells 1. 2. 3. COA AAR for CY 2009; COA AAR for CY 2010; Letter of the Respondent Corona dated December 6, 2010 to COA Chaiman Villar; 4. Letter of COA Assistant Commissioner and General Counsel Elizabeth Zosa dated July 6, 2011 to Respondent Corona; and 5. Letter of SC OCA Midas Marquez dated August 5, 2011 addressed to COA Chairperson GracePulido-Tan.

B.

With reference to the testimony of Lilianne Ulgado and Corazon Ferrer-Flores 1. 2. 3. 4. 5. 6. Supreme Court’s Financial Statements; SC’s Books of Accounts for the CFAG for the years 2010 and 2011; SC’s Journal Entry Vouchers for 2009, 2010 and 2011; SC’s Personal Services Itemization and Plantilla of Personnel (PSIPOP); SC-Memorandum Order No. 22-2010 dated 21 May 2010; SC-Memorandum Order 22-A-2010 dated 21 May 2010;

39 7. 8. 9. 10. 11. 12. 13. SC-Memorandum Order No 27-2010 dated 7 June 2010; SC-Memorandum Order No. 27-A-2010 dated 7 June 2010; SC-Memorandum Order No. 49-2010 dated 20 October 2010; SC-Memorandum Order 56-2010 dated 6 December 2010; SC-Memorandum Order No 56-A-2010 dated 6 December 2010; SC-Memorandum Order No. 57-2010 dated 16 December 2010; and SC-Memorandum Order No. 57-A-2010 dated 16 December 2010

RESERVATIONS

The prosecution reserves the right to present additional documents and witnesses, or to dispense with some of the identified documents and witnesses, during the course of the trial, as the need arises or as may be subject to stipulation.

The prosecution likewise reserves the right to offer the abovementioned witnesses and documents for additional purposes as may be necessary.

Some of the intended witnesses cannot be named or included in the list at present due to security concerns.

RESPECTFULLY SUBMITTED Pasay City, Metro Manila, January 27, 2012.

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