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SENATE

'12 JAN 27 P 3 :35

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,

REPRESENTATIVES NIEL C. TUPAS,

JR., JOSEPH EMILIO A. ABAYA,

LORENZO R. T ANADA, III,

REYNALDO V. UMALI, ARLENE J.

BAG-AO (other complainantscomprising one third (1/3) of the

total Members of the House of

Representatives as are indicated

below.)

h:;;{'<'" v;, ,,- oy f7l. --.... " " ~ : U t 4 ~ ' 1 I c --

CASE NO, 002-2011

x -------------------------------------------------------------------------------------------------------- x

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 jI list of witnesses and documentary evidence to be

presented in the course of the trial (in addition to those already presented thus far).2

1 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.



ARTICLE IList of Witnesses

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

Malacaiiang, 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, Malacaiiang, 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 ofthe Constitution.

5. Ms. Donna Z. Pazzibugan, Philippine Daily Inquirer, Chino Roces Avenue corner

Vague and Mascardo Streets, Makati City. - As a Malacanang accredited reporter for the POI,

she will testify and prove that during the oath-taking of CJ Corona in Malacanang 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 ofMr. 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 ofAtty. 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 ofMs. 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 Makat i 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 Renata 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 Renata 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 Renata C. Corona and Cristina R. Corona of Burgundy Katipunan

condominium unit.

6. Records Officer of John Hay Management Corp. - He/she will test ify 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 theCertificate 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. Bank Representatives of BPI, PNB and Land Bank - They will testify on the

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

11. Ms. Mary Eleonor A. Mendoza, Vice-President, Filinvest Alabang, Inc. - She will

testify on the execution of the Contract To Sell Common Share between Filinvest Alabang, Inc.

and Spouses Renata C. Corona and Cristina R. Corona dated July 14, 2006 covering one (1)

common share of The Palms Country Club, Inc.



5

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 Renata C. Corona and Cristina R. Corona notarized on September 11, 2009

covering one {1} common share ofthe The Palms Country Club, Inc.

13. Certified Fraud Examiner (CFE) - He/she will render expert opinion on the true or

correct Net Worth of Renata 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.


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. Buyer's Information Sheet;

4. Contract To Sell;

5. Various Official Receipts; and

6. Deed of Absolute Sale.

B. With reference to The Bel/agio 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. Contract to Buy and Sell;

3. Request for Reservation and Offer to Purchase;

4. Various Official Receipts;

5. Deed of Assignment;



6

6. Letter-request dated September 8, 2004; and

7. Buyer's Information Sheet.

C. With reference to the Bonifacio Ridge property to be testified to by Aniceto Visnar Jr.

1. Buyer's Information Sheet;

2. Various Official Receipts;

3. Deed of Absolute Sale; and

4. Certificate Authorizing Registration and Documentary Stamp Tax Declaration.

D. With reference to the Burgundy property to be testified to be Greg Gregonia

1. Reservation Application;

2. Contract To Sell;

3. Statement of Account with Various Official Receipts;

4. Deedof

Absolute Sale;

5. Acknowledgement of Unit Completion and Acceptance;

6. Agreement to Allot Parking Slot; and

7. 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. Certificate of Live Birth of Ma. Carla R. Corona-Castillo;

2. Certificate of Live Birth of Ma. Charina R. Corona; and

3. 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



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1. Articles of Incorporation

2. General Information Sheets (GIS)

3. Audited Financial Statements

4. Other documents

H. With reference to the testimony of the Representative of the Housing Land Use

Regulatory Board

1. Records on file of The Bellagio;

2. Records on file of Bonifacio Ridge;

3. Records on file of Mckinley Hill; and

4. 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 Renata C. Corona and Cristina R. Corona;

and

2. Monthly Bank Statements of Renata C. Corona and Cristina R. Corona.

J. With reference to the sale of the one (1) common shore of The Palms Country Club

between Fillnvest Alabang, Inc. and Sps. Renata C. Corona and Cristina R. Corona

1. Contract To Sell Common Share between Filinvest Alabang, Inc.

and Spouses Renata 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

Renata 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 "AU Share issued to Spouses Renata 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 Renata 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 PI00,000.00

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 se Resident

eOA 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. eorazon 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.



9

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

CRlliTINA CORONA CJ RENATa CORONA" amounting to P20,400; and (b) Design EXCHANGE

Incorporated Sales Invoice No. 4920 dated June 29, 2010 under the name "RENATa CORONA

CRlliTINA CORONA" amounting to P25,000;

6. The Corporate Secretary or Assistant Corporate Secretary of John Hay

Management Corporation - He/she will provide a short corporate background of JHMC and

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 test ify 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 test ify 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 Administra tor 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.

, Mr. Daytec filed a criminal case against Mrs. Corona and the Respondent; the case docketed as Frank Daytec vs.

Mo. Cristina Corona and Renato Corona, NPS Docket No, XVI-INV-llG-00247 is pending preliminary investigation

at the DOJ.



11

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.


A. With reference to the testimony ofAtty. Gorgonio B. Elarmo Jr



12

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 PlOO,OOO.OO 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 ofCorazon G. Ferrer-Flores

1. The original and certified true copies of the "MEMORANDUM FOR: HaN.

RENATa C. CORONA" dated July 16, 2010 on the "Proposed Augmentation of

Gasoline Expense Allowance", and all other memoranda fo r 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 OfficerofShangrila 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



13

1. Design EXCHANGE Incorporated Sales Invoice No. 4874 dated June 10, 2010

under the name" c/o CRISTIPJA 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. Original Minutes ofthe Board Meeting of JHMC held on April 3, 2007;

2. Original letter of Executive Secretary Eduardo Ermita dated March 29, 2007;

3. Original desire letter of former President Gloria M. Arroyo dated March 23,

2007, for the election of Mrs. Corona as Chairman and President;

4. Original Letter of Executive Secretary Eduardo Ermita dated July 12, 2007;

5. Original desire letter of PGMA dated July 12, 2007, fo r election of Mrs. Corona as

OIC, Office of the Chairman;

6. Original letter of Executive Secretary Eduardo Ermita dated July 12, 2007;

7. 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 ofAtty. Lyssa GS Pagano Calde

1. Original Position Paper dated May 29,2007; and

2. Original Position Paper dated June 4, 2007.

G. With reference to the testimony of Former CA Justice Teodora P. Regino

1. Original Resolution No. 2007-05-38;

2. 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-Dimaglba, COA Dir.

Rosemarie Lacson-Lerio, and COA Suprevising Auditor Atty. Arlyn M. Encarnacion

1. Original Annual Audit Report of JHMC for the year ending December 31, 2007;

2. Original Annual Audit Report of JHMC fo r the year ending December 31,2008;

3. Original Annual Audit Report of JHMC fo r the year ending December 31, 2009;

and

4. Original Annual Audit Report of JHMC fo r the year ending December 31, 2010.

I. 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 afFrank Day tee

1. BCC O.R. No. 279937 dated March 14, 2007;

2. BCC O.R. No. 348463 dated March 14, 2010;

3. Disbursement Voucher No. 2010-06-756; and

4. 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

informat ion 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 presentedto

showthat the

affidavitsof

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. Letters of FASAP and Atty. Estelito Mendoza.

M. With reference to the testimony ofAtty. Enriqueta Vidal

1. RollO/Records of FASAP case (G.R. 178083);

2. 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. Raila/Records of A.M. No. 11-10-1-SC; and

S. 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. Travel bookings of Renato and Cristina Corona through Prestige Travel Agency.

3. 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

of Docket Division, Judicial Records Office, An Officer of the Docket Division and An Officer of

the Rollo Room - They will testify on the process of receipt of petition, pleadings, raffle

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 ofthe copies ofthe 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, At tendant, Supreme Court En Bane 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. 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.

193459.



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 ofthe Supreme Court in the March 15, 2011 en banc session.


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.

B. With reference to the testimonies of Felipa Anama, The Records Officer, ReceivingSection 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. Rollo/Records of the Merceditas Gutierrez case (G.R. No. 193459);

3. Agenda and minutes ofthe en banc session of September 14,2010; and

4. The "Detailed Report" "Synopsis" ofthe member-in-charge in G.R. No. 193459.

C. With reference to the testimony ofJohnny Aquino

1. Delivery receipt/logbook used by Johnny Aquino; and

2. 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. Official answer to Rep. Farinas' letter dated March 15, 2011; and

4. 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 udgments; (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 ofthe 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 ofCities case in the agenda of the En Bane.

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 Bane 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 bane 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 bane; (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 Bane; (10) to testify on



19

Corona's participation in A.M. No. 11-1O-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 he 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 ofCities 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 udgment, 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 he En Bane.

4. A former Justice of he 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 he En Banc.

5. A Former Justice of the Supreme Court or other legal expert - who will testify on the

rules on finality of udgment, rules on Motions for Reconsideration, the propriety of transmitting private

letters to the Supreme Court and the internal procedures ofthe Supreme Court pursuant to which Corona

included the FASAP case in the agenda of he En Banc.

6. Responsible officials, employees, and staff of the Supreme Court and its departments

and divisions - who are privy to the proceedings and deliberations in the League ofCities 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 bane; 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 ts 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 (S) that FASAP was not asked to cornment on the said letters

before the suprerne Court acted on the same.

Documentarv 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. COMELEe.

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 Leogue of Cities v.

COMELEC - To show that members of the Supreme Court En Bane 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 Leogue 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 udgments and intervention.

5. Sworn statements of responsible Supreme Court officials, employees, and staff

privy to the proceedings and deliberations in Navarro v. Ermita - To prove

respondent Corona's direct acts and involvement in disregarding the finality of udgments

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 - To show that the letter from

Estelito Mendoza is instrumental in the later recall of the Resolutions dated 02

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.



22

5. Memorandum written by the Clerk of Court of the Supreme Court En Bane 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 - To show that Corona had initially inhibited

himself from the FASAP Case.

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 amember 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 Bane regarding the FASAP Case - To establish facts surrounding the

decision in A.M. No. 11-10-1-SC.

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 01. - To prove

respondent Corona's direct acts and involvement in influencing the other Members of he

Supreme Court En Bane 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.


A. With reference to the testimony ofAtty. Enriqueta Esguerra-Vidal

1. 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. 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 band c above), including all the concurring and

dissenting opinions of the other justices, if there are any;

S. 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 Resolutionof

the Supreme Court dated October 12, 2010 in A.M. No. 10-7-17-5C, including all the concurring and dissenting opinions ofthe other justices, if

there are any;

9. The Resolution of the Supreme Court dated February 8, 2011 in A.M. No. 10-7-

17-5C; 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 attestto

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 test ify, 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 is 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


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 fil ing 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 Bane - 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 ofthe Clerk of Court ofthe payment ofthe 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. a Iowing 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 dear 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 Administra tor 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 (Le. 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 (Le. 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

viewof

a clear failureto

comply with the conditionsof

the Supreme Court amountedto

abetrayal 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


relevant to the instant case.



30

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




betrayal of public trust. This was made possible through respondent's individual acts of: (i)





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









22. Justice Arturo D. Brion - He will testify, among others: (1) That the hurried




betrayalof

public trust. This was made possible through respondent's individual acts of: (i)





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








31




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; Iii)

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 onthe

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


24. Other Supreme Court Officials and media personnel who may be determined

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


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 ofthe 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;


2011;

14. Resolution dated 18 November 2011 issued on the GMA and Mike Arroyo TRO

Petition, as published;


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 Modificationsof

Justice Velasco's draft on the GMAand 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 Bane;

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


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. Dissenting Opinion of Justice Abad in G.R. No. 199034 and 199046 as published;

27. 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 PresbiteroJ.

Velasco, the dissenting opinionof

Associate JusticeMaria 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 non

promulgation 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. Official Appointment of Respondent Corona as Chief Justice;

36. 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 ArroyoTRO

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 Appointmentof

Justice Roberto A. Abad as Justiceof

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 favorof

Atty. Ferdinand Topacio appointinghim "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. News Videos showing the implementation of the TRO;

50. Doctor Certificate showing the diagnosis of GMA;

51. 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 testi fy 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'sJudidal Refurm Support Project -who will testify, among

others, on: (1) the authenticity and contents ofthe Report of the Wortd Bank Implementation Support Mission for the

JRSP; (2) the various questionable expenditures incurred by respondent Corona, which are indida of he 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)othermatters relevant to the instant case.


A. With reference to the testimonies of Lourdes Lim and Myrna Cells

1. COA AAR fo r CY 2009;

2. COA AAR fo r CY 2010;

3. 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 Uigado and Corazon Ferrer-Flores

1. Supreme Court's Financial Statements;

2. SC's Books of Accounts fo r the CFAG fo r the years 2010 and 2011;

3. SC's Journal Entry Vouchers fo r 2009, 2010 and 2011;

4. SC's Personal Services Itemization and Plantilla of Personnel (PSI POP);

5. SC-Memorandum Order No. 22-2010 dated 21 May 2010;

6. SC-Memorandum Order 22-A-2010 dated 21 May 2010;



7. SC-Memorandum Order No 27-2010 dated 7 June 2010;

8. SC-Memorandum Order No. 27-A-201O dated 7 June 2010;

9. SC-Memorandum Order No. 49-2010 dated 20 October 2010;

10. SC-Memorandum Order 56-2010 dated 6 December 2010;

11. SC-Memorandum Order No 56-A-201O dated 6 December 2010;

12. SC-Memorandum Order No. 57-2010 dated 16 December 2010; and

13. SC-Memorandum Order No. 57-A-201O 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 fo r 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 SUBMITIED

Pasay City, Metro Manila, January 27, 2012.



•

THE HOUSE OF REPRESENTATIVESRepublic of the Philippines

By:

HOUSE OF REPRESENTATIVESPR ECUTO",,:"'L.--

Copy Furnished (By Personal Service):

Justice Serafin R. Cuevas (Ret.) et al.

PRIVATEPROSECUTORS

MARIO LUZA BAUTISTAPTR No. 2686005, Jan. 18, 2011, Makati

CityLifetime IBP No. 00060, Makati City

Roll of Attorneys No. 30196

MCLE Compliance No. 1110008479, Feb. 9,2010

Counsel for Respondent Chief Justice Renato Corona

Suite 1902 Security Bank Centre6776 Ayala Avenue

Makati City, Philippines 1226

compliance jan27 p335

Documents