Final List of Witnesses in Corona Impeachment Trial

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    REPUBLIC OF THE PHILIPPINES

    CONGRESS OF THE PHILIPPINES

    SENATE

    SITTING AS THE IMPEACHMENT COURT

    IN THE MATTER OF THEIMPEACHMENT OF RENATO C.CORONA AS CHIEF JUSTICE OF THESUPREME COURT OF THEPHILIPPINES,

    REPRESENTATIVES NIEL C. TUPAS,JR., JOSEPH EMILIO A. ABAYA,LORENZO R. TAADA, III,REYNALDO V. UMALI, ARLENE J.

    BAG-AO (other complainantscomprising one third (1/3) of thetotal Members of the House ofRepresentatives as are indicatedbelow.)

    CASE NO. 002-2011

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

    The HOUSE OF REPRESENTATIVES, through its PROSECUTORS, respectfully submits the

    instant Compliance to the Order

    COMPLIANCE

    1of 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

    1TSN, 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,

    Malacaang, Manila - He will identify CJ Coronas 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

    Coronas 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, Malacaang, 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 Malacaang accredited reporter for the PDI,

    she will testify and prove that during the oath-taking of CJ Corona in Malacaang 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

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    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 ConstitutionalCommission.

    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 ConstitutionalCommission.

    ARTICLE II

    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

    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.

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    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 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 Renato 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 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.

    A. With reference to The Columns property to be testified to by The Register of Deeds ofMakati City and Nerissa J. Josef

    Documentary Evidence

    1. Condominium Certificate of Title No. 85716 in the name of CristinaR. Corona;

    2. Deed of Absolute Sale between Community Innovations, Inc. andCristina R. Corona dated October 1, 2004;

    3. Buyers Information Sheet;4. Contract To Sell;5. Various Official Receipts; and6.

    Deed of Absolute Sale.

    B. With reference to The Bellagio and McKinley property to be testified to by Giovanni Ng1. 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;

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    6. Letter-request dated September 8, 2004; and7. Buyers Information Sheet.

    C. With reference to the Bonifacio Ridge property to be testified to by Aniceto Visnar Jr.1. Buyers 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. Deed of 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 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 SpousesRenato 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 FilinvestAlabang, Inc.; and

    4. The Palms Country Club Class A Share issued to Spouses Renato C. Corona andCristina R. Corona.

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    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 spouses 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 Officerand/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

    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 Rustans 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 Rustans Office.

    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.

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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

    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

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    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. Coronas 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

    3

    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.

    (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 latters chamber sometime in September 2010.

    During said meeting, CJ divulged information regarding Mr. Vizcondes 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.

    Mendozas letters as well as the circumstances concerning FASAPs 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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    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 Mendozas letters as an

    Administrative Matter (A.M.) case.

    20. Felipa Anama, Deputy Clerk of Court of the Supreme Court - corroborating

    Clerk of Court Vidals 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 of Atty. Gorgonio B. Elarmo Jr

    Documentary Evidence

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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 documentspertaining 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

    3. Other pertinent documents pertaining to this transaction on file with RustansOffice.

    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

    Rustans Itemized List consisting of nineteen (19) items;

    2. The pertinent Bridal/Gift registry on the 60th

    Wedding Anniversary of James and

    Julie Dy, and

    D. With reference to the testimony of the Owner/Manager Representative of DesignExchange Incorporated

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    1. Design EXCHANGE Incorporated Sales Invoice No. 4874 dated June 10, 2010under 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, 2010under 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 of the 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, for 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 of Atty. 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 Teodoro P. Regino

    1. Original Resolution No. 2007-05-38;2. Resignation Letter of Teodoro Regino dated June 20, 2007, addressed to PGMA.

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    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. Original Annual Audit Report of JHMC for the year ending December 31, 2007;2. Original Annual Audit Report of JHMC for the year ending December 31, 2008;3. Original Annual Audit Report of JHMC for the year ending December 31, 2009;

    and

    4. Original Annual Audit Report of JHMC for 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 of Frank Daytec

    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; and4. 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 SupremeCourt 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 SupremeCourt dated January 18, 2011, subscribed and sworn to on 26 January 2011. This

    document will be presented to corroborate the statements made in Mr.

    Vizcondes affidavit stating that CJ Corona met with him and Lauro Vizconde

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    sometime in September 2010 and that CJ divulged information regarding Mr.

    Vizcondes 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. LauroVizconde 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 relevantto the FASAP case; and

    2. Letters of FASAP and Atty. Estelito Mendoza.

    M. With reference to the testimony of Atty. 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 theFASAP case;

    4. Rollo/Records of A.M. No. 11-10-1-SC; and5. Agenda and minutes of the en banc session on 4 October 2011.

    N. With reference to the travel records of respondent Corona by PAL

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    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 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. 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.

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    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.

    1. Letter of Justice Antonio Carpio to Court Administrator Midas Marquez, dated 4March 2011; and

    Documentary Evidence

    A. With reference to the testimony of Court Administrator Jose Midas Marquez

    2. Press Statement of Justice Maria Lourdes Sereno, dated 9 March 2011, andCorrigendum 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 stampRECEIVED;

    2. Rollo/Records of the Merceditas Gutierrez case (G.R. No. 193459);3. Agenda and minutes of the en banc session of September 14, 2010; and4. The Detailed Report/Synopsis of the member-in-charge in G.R. No. 193459.

    C. With reference to the testimony of Johnny Aquino

    1. Delivery receipt/logbook used by Johnny Aquino; and2. 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;

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    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; and4. Agenda and minutes of March 15, 2011 en banc session.

    ARTICLE V

    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

    List of Witnesses

    1. Atty. Enriqueta Vidal, Clerk of Court, Supreme CourtShe 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.

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    Coronas 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 NavarroCase 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. 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 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

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    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.

    5. Certified True Copy of the Resolution dated 15 February 2011 in League of Citiesv. 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.

    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 theblatant error in the previous ruling, thus, reinstating the original Decision dated

    18 November 2008.

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    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 - To prove

    respondent Coronas direct acts and involvement in disregarding the finality of judgments

    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 September2011. - To prove that the Decision dated 22 July 2008 became final after the

    Supreme Court denied, with finality, PALs Motions for Reconsideration.

    3. Personal letter submitted to the Supreme Court by Estelito Mendoza, PALslawyer, 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 02October 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.

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    5. Memorandum written by the Clerk of Court of the Supreme Court En Banc dated26 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 Coronas 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 inhibitedhimself from the FASAP Case.

    7. Minutes of the Raffle Committee of 11 November 2009, a list of membersthereof 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 SupremeCourt En Banc 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, andthe Supreme Courts 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 staffprivy to the proceedings and deliberations in Flight Attendants and StewardsAssociation of the Philippines(FASAP) v. Philippine Airlines, Inc., et al. - To prove

    respondent Coronas 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

    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

    List of Witnesses

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    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 of Atty. Enriqueta Esguerra-Vidal

    Documentary Evidence

    1. Decision dated April 28, 2010 in Isabelita C. Vinuya versus the HonorableExecutive 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. Vinuyaversus the Honorable Executive Secretary Alberto G. Romulo docketed as G.R.

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    No. 162230;

    3. The Supplemental Motion for Reconsideration filed by the petitioners in IsabelitaC. 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 Motionfor 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, showingthe jurisdiction of such Committee;

    6. Resolution activating the Ethics Committee to investigate Associate Justice delCastillo 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. 10-7-17-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. 10-7-17-SC; and

    10. An inventory of administrative complainants filed against justices of the SupremeCourt, 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

    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

    List of Witnesses

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    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 variouscriminal 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. JulietGopez-Cervantes - who will attest to GMAs 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 GMAs continuing recovery and her positiveprognosis, 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 theworking 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) Thatthe 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

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    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) Thatthe 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 allowingGMA 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 infavor 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

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    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 theTRO 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 respondentCorona 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 willtestify, among others: (1) that Respondent Corona made handwritten corrections on the

    typewritten draft Resolution Justice Velasco with the instruction that the Chief Justices 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 servedthe TRO He will testify, among others: (1) That respondent Corona in order to immediately

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    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 on15 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 at8:55am 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 willtestify 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 thehurried 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 respondents 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 onhis 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

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    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 Justices 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 hurriedissuance 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 atyrannical abuse of power, an act of favoritism and an inexcusably negligent act amounting to a

    betrayal of public trust. This was made possible through respondents 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 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 Justices 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.

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    21. Justice Bienvenido Reyes He will testify, among others: (1) That the hurriedissuance 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 respondents 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 Justices 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 mattersrelevant to the instant case.

    22. Justice Arturo D. Brion He will testify, among others: (1) That the hurriedissuance 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 respondents 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 Justices version is to be immediately promulgated;

    and (3) On the allegations contained in the Verified Complaint, and other pleadings filed by

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    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 thehurried 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 respondents 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 thetypewritten draft Resolution Justice Velasco with the instruction that the Chief Justices 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 determinedas 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;

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    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 summonsor 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 Sheriffs 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;

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    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. Carpios Modifications of Justice Velascos draft on the GMAand Mike Arroyo TRO Petition;

    18. Respondent Coronas handwritten corrections on Justice Velascos draft on the

    GMA and Mike Arroyo TRO Petition dated 22 November 2011 with the

    instruction that the Chief Justices 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 Serenos 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;

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    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. 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 Presbitero J. Velasco, the dissenting opinion of 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 theClerk 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;

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    33. Certified True Copy of G.R. No. 197930 where the Supreme Court denied Efraim

    Genuinos 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 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;

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    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 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 MacapagalArroyo 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

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    filing these conditions or once they are able to comply with these conditions,

    they can fly already,"

    ARTICLE VIII

    2. Department of Budget and Management (or Civil Service Commission) RecordsCustodian 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.

    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

    AARs and that Respondent Chief Justice asked COA not to publish the AARs 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.

    3. Ms. Lilianne E. Ulgado, SCs Chief Accountant - She will testify, amongothers, on the contents of the Supreme Courts Financial Statements; that funds allocated for

    Personal Services, MOOE in the SCPs 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 SCs Fiscal Management and BudgetOffice (FMBO) - She will testify as to the declaration of the Managements Responsibility for

    Financial Statements of SC and its significance and to corroborate the testimony of Ms. Ulgado.

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    5. COA Auditor for the Fiscal Autonomy Fund (CFAG Fund) - She will testify tocorroborate the testimony of Ms. Ulgado; that in the performance of her duties and

    responsibilities, she conducted and audit on the SCs CFAG Fund; Her audit findings on the SCs

    CFAG Funds.

    6. Representative of the World Banks Judicial Reform Support Project who will testify, amongothers, 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 instant case.

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

    1. COA AAR for CY 2009;2. COA AAR for 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 datedJuly 6, 2011 to Respondent Corona; and

    5. Letter of SC OCA Midas Marquez dated August 5, 2011 addressed to COAChairperson GracePulido-Tan.

    B. With reference to the testimony of Lilianne Ulgado and Corazon Ferrer-Flores

    1. Supreme Courts Financial Statements;2. SCs Books of Accounts for the CFAG for the years 2010 and 2011;3. SCs Journal Entry Vouchers for 2009, 2010 and 2011;4. SCs Personal Services Itemization and Plantilla of Personnel (PSIPOP);5. SC-Memorandum Order No. 22-2010 dated 21 May 2010;6. SC-Memorandum Order 22-A-2010 dated 21 May 2010;

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    7. SC-Memorandum Order No 27-2010 dated 7 June 2010;8. SC-Memorandum Order No. 27-A-2010 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-2010 dated 6 December 2010;12. SC-Memorandum Order No. 57-2010 dated 16 December 2010; and13. 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.