REPUBLIC OF THE PHILIPPINES

Congress of the Philippines

Senate
SITTING AS THE IMPEACHMENT TRIBUNAL
IN THE MATTER OF THE
IMPEACHMENT OF RENATO C.
CORONA AS CHIEF JUSTICE OF
THE SUPREME COURT OF THE
PHILIPPINES
'1 i FEB - 7 P 4 :41
Case No. 002-2011
REPRESENTATIVES NIEl C,
TUPAS, JR. (other complainants
comprising at least one third
(1/3) of the total Members of
the House or Representatives as
are indicated below,)
x-----------------------------------------------------------x
REQUEST FOR ISSUANCE OF
SUBPOENA Duces Tecum
In relation to the instant impeachment proceedings, The HOUSE OF
REPRESENATIVES respectfully requests for the issuance of subpoena duces
tecum requiring GING REYES, head of the ABS-CBN News and Current
Affairs Division, or the designated official custodian of the documents or
videos stated hereunder with office address at: ABS-CBN Broadcast Center,
Sgt. Esguerra Ave. corner Mother Ignacia St., Barangay Laging Handa,
Diliman, Quezon City, Philippines, to bring on February 9, 2012 at 10:00
a.m. or on such date and time as may be determined by the Honorable
Impeachment Tribunal at the Senate Session Hall, Senate of the Philippines,
Pasay City, the following:
1. Video of the Press briefing of Supreme Court Midas Marquez
on 15 November 2011 at around 1:30 pm wherein he made the
announcement that: (a) the Supreme Court, through an 8-5 ruling, decided
to issue a Temporary Restraining Order [TROj in favor of Gloria Macapagal
Arroyo [GMAj in connection with her inclusion in the watch-list order
[WLOj of the DOl, (b) that among those who voted for said issuance is Chief
Justice Renata C. Corona, (c) that after compliance with the 2 conditions
imposed in the TRO, to wit: posting of bond and submission by GMA of SPA,
GMA may already leave the country, (d) that Midas Marquez admitted
during said press briefing that the Supreme Court was still drafting the
resolution as of said time;
2. Video showing Atty. Ferdinand Topacio preparing for the
payment of cash bond on 15 November 2011 at around 5:00 pm to 7:00
pm;
3. Video showing the posting / payment of cash bond at the
Supreme Court made by GMA, through her representative, on 15
November 2011 at around 6:00 pm, in relation to the TRO issued by the
Supreme Court in her favor;
4. Video showing the attempted travel of Former President Gloria
Macapagal Arroyo (GMA) on 15 November 2011 from the time she left the
hospital to the time she arrived at the airport;
5. Video showing the arrest of GMA by virtue of a warrant of
arrest issued by Judge Jesus Mupas of Branch 112 of the Regional Trial
Court of Pasay City;
6. Video showing the statement of Midas Marquez on November
16,2011 in Head Start stating that the TRO is still in full force and effect;
7. Video showing the statements of Midas Marquez in reaction to
the allegations that he made untruthful statements regarding the TRO
issued in favor of GMA made on November 20, 2011;
8. List of cameramen who covered said incidents as above-stated;
Said documents and videos are being required for the purpose of
proving, 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) That statements were made by the Public Information
Office of the Supreme Court relating to the TRO; (5) That SC spokesperson
Midas Marquez announced to the media (through a press conference) the
8-5 ruling in favor of a TRO against Arroyo's WLO, though said resolution
was still being drafted; (6) The manner 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) The allegations contained in the Verified Complaint, and other
pleadings filed by complainants, and other matters relevant to the instant
case.
Respectfully Submitted,
Pasay City, February 7, 2012.
HOUSE OF REPRESENTATIVES
Prosecution Panel
Ambrosio Padilla Hall
2
nd
Floor, GSIS Bldg., Financial Center
Roxas Blvd., Pasay City
By:
essman, 5
th
District, II ilo
Chairman, Committee on Justice
Lead Prosecutor
Copy furnished (By personal service)
Justice Serafin R. Cuevas (Ret.) et al.
Counsel for Respondent Chief Justice Renato Corona
Suite 1902 Security Bank Centre
6776 Ayala Avenue
Makati City, Philippines 1226
;/\ 106lrOW &
,tN-
1