REPUBLIC OF THE PHILIPPINES Congress of the Philippines Senate SITTING AS THE IMPEACHMENT TRIBUNAIj2

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IN THE MATTER OF THE IMPEACHMENT OF RENATO C. CORONA AS CHIEF JUSTICE OF THE SUPREME COURT OF THE PHILIPPINES Case No. 002-2011 REPRESENTATIVES NIEL C. TUPAS (other complainants comprising at least one third (1/3) of the total Members of the House or Representatives as are indicated below.)

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REQUEST FOR SUBPOENA Duces Tecum In relation to the instant impeachment proceedings, The HOUSE OF REPRESENATIVES respectfully request for the issuance of subpoena duces tmlm requiring ENRIQUETA E. VIDAL, Clerk of Court of the Supreme Court En Bane with office address at: SUPREME COURT, PADRE FAURA STREET, MANILA to bring on 7 February 2012 at 10:00 a.m. or on such date and time as may be determined by the Honorable Impeachment Tribunal at the Senate Session Hall, Senate of the Philippines, Pasay City, official and/or certified true copies of the following documents:

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

Purpose To show, among others, that respondent Corona rushed the issuance of the TRO against the DO] on 15 November 2011 give the Arroyos an 1U order to opportunity to escape prosecution and to frustrate ends justice.; of the Respondent Corona promulgated a verSlOn of the En Bane decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape

2.

Supreme Court received (with

To

show,

among

others,

that

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 PreJiminary Injunction docketed as (G.R. No. 199046) [Mike Arroyo TRO Petition), including the Annexes thereto;

respondent Corona rushed the issuance of the TRO against the DOJ on 15 November 2011 in order to give the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice; Respondent Corona promulgated a version of the En Banc decision that is contralY to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape

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Respondent Corona's travel To show, among others, that respondent order or leave applied for within Corona rushed back to the Philippines for the issuance of the TRO against the the month of November 2011; DO] on 15 November 2011 in order to g1ve the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice To show, among others, that respondent Minutes of the Supreme Court Raffle Committee which handled Corona rushed the issuance of the TRO the GMA and Mike Arroyo TRO against the DOJ on 15 November 2011 1n order to g1ve the Arroyos an Petition; opportunity to escape prosecution and to of justice; frustrate the ends Respondent Corona promulgated a version of the En Banc decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape Appointment or Assignment of To show, among others, that respondent the Member-in-Charge of the Corona rushed the issuance of the TRO GMA and Mike Arroyo TRO against the DO] on 15 November 2011 Petition; 1n order to g1ve the Arroyos an opportunity to escape prosecution and to of justice; frustrate the ends Respondent Corona promulgated a version of the En Banc decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape Notes of respondent Corona To show, among others, that respondent during the 15 November 2011 Corona rushed the issuance of the TRO Supreme Court En Banc Session against the DO] on 15 November 2011 on the GMA and Mike Arroyo 1n order to glVe the Arroyos an TRO Petition (which under the opportunity to escape prosecution and to Internal Rules should be given to frustrate of justice; the ends the Clerk of Court since it is the Respondent Corona promulgated a basis for drafting Minutes and version of the En Banc decision that is resolutions); contralY to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape Agenda and Minutes of the 15 To show, among others, that respondent November 2011 Supreme Court Corona rushed the issuance of the TRO En Banc Session on the GMA against the DOl on 15 November 2011

order to glVe the Arroyos an opportunity to escape prosecution and to of justice; frustrate the ends Respondent Corona promulgated a version of the En Banc decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedv escape 8. Resolution dated 15 November To show, among others, that respondent 2011 ill the GMA and Mike Corona rushed the issuance of the TRO against the DOJ on 15 November 2011 Arroyo TRO Petition; ill order to glVe the Arroyos an opportunity to escape prosecution and to of justice; frustrate the ends Respondent Corona promulgated a version of the En Bane decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape To show, among others, that respondent 9. Temporary Restraining Order dated 15 November 2011 issued Corona rushed the issuance of the TRO in the GMA and Mike Arroyo against the DOJ on 15 November 2011 ill order to give the Arroyos an TRO Petition; opportunity to escape prosecution and to frustrate the ends of justice; Respondent Corona promulgated a version of the En Bane decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape 10. Logbook or receiving copy To show, among others, that respondent showing the time the TRO was Corona rushed the issuance of the TRO issued to the counsel for GMA against the DOJ on 15 November 2011 and Mike Arroyo as well as the In order to give the Arroyos an date and time the TRO was opportunity to escape prosecution and to of justice; the ends received by the Sheriff for frustrate Respondent Corona promulgated a service to the parties; version of the En Bane decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape 11. Speda/ Power of AttoTnry dated 15 To show, among others, that respondent November 2011 submitted by Corona rushed the issuance of the TRO GMA and Mike Arroyo in favor against the DOJ on 15 November 2011 of Atty. Ferdinand Topacio and In order to give the Arroyos an Anacleto M. Diaz in compliance opportunity to escape prosecution and to the ends with the TRO dated 15 frustrate of justice; November 2011; Respondent Corona promulgated a version of the En Banc decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape 12. Official Receipt No. 00300227- To show, among others, that respondent and Mike Arroyo TRO Petition;
ill

SC-EP dated 15 November 2011 Corona rushed the issuance of the TRO issued by tbe Supreme Court for against the DOJ on 15 November 2011 tbe Two Million Pesos Cash In order to give the Arroyos an Bond of GMA and Mike Arroyo opportunity to escape prosecution and to of justice; the ends witb tbe official date and time frustrate Respondent Corona promulgated a stamp; version of the En Banc decision tbat is contrary to the manner of voting by tbe Justices; and Respondent used bis votes to favor GMA and her husband to ensure their speedy escape 13. November 15 and 16, 2011 To show, among otbers, that respondent Sheriffs Return of service of tbe Corona rushed the issuance of the TRO GMA and Mike Arroyo TRO against the DOJ on 15 November 2011 dated 15 November 2011 upon In order to glVe the Arroyos an tbe Department of Justice and opportunity to escape prosecution and to the ends of justice; the Office of the Solicitor frustrate Respondent Corona promulgated a General; version of the En Banc decision tbat is contrary to tbe manner of voting by tbe Justices; and Respondent used his votes to favor GMA and her husband to ensure tbeir speedy escape 14. Certification from tbe Fiscal To show, among others, that respondent Management and Budget Office Corona rushed the issuance of the TRO of tbe Supreme Court dated against the DOJ on 15 November 2011 November 15, 2011 with tbe in order to give the Arroyos an date and time it was received by opportunity to escape prosecution and to tbe ends of justice; tbe Supreme Court Clerk of frustrate Court showing it to be Respondent Corona promulgated a version of the En Banc decision tbat is November 16, 2011 at 8:55am; contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape 15. Notes of respondent Corona of To show, among others, that respondent the 18 November 2011 Supreme Corona rushed tbe issuance of tbe TRO Court En Banc Session on tbe against the DOJ on 15 November 2011 GMA and Mike Arroyo TRO In order to give the Arroyos an Petition; opportunity to escape prosecution and to frustrate the ends of justice; Respondent Corona promulgated a version of the En Banc decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape 16. Agenda and Minutes of the 18 To show, among others, that respondent November 2011 Supreme Court Corona rushed the issuance of the TRO En Banc Session; against the DO] on 15 November 2011
1n

order

to

give

the

Arroyos

an

opportunity to escape prosecution and to frustrate the ends of justice; Respondent Corona promulgated a verSiOn of tbe En Bane decision that is contrary to tbe manner of voting by the Justices; and Respondent used bis votes to favor GMA and her husband to

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ensure their speedy escape 17. Resolution dated 18 November To show, among others, that respondent 2011 issued in the GMA and Corona mshed the issuance of the TRO against the DOJ on 15 November 2011 Mike Arroyo TRO Petition; 111 order to give the Arroyos an opportunity to escape prosecution and to of justice; frustrate the ends Respondent Corona promulgated a version of tbe En Bane decision that is contrary to tbe manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy esclle To show, among others, that respondent Corona rushed the issuance of tbe TRO 18. Notes of respondent Corona of tbe 22 November 2011 Supreme against the DOJ on 15 November 2011 Court En Bane Session on tbe in order to give the Arroyos an GMA and Mike Arroyo TRO opportunity to escape prosecution and to of justice; frustrate the ends Petition; Respondent Corona promulgated a version of the En Bane decision tbat is contrary to tbe manner of voting by tbe Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape 19. Agenda and Minutes of the 22 To show, among otbers, that respondent November 2011 Supreme Court Corona rushed tbe issuance of the TRO En Banc Session on tbe GMA against tbe DOJ on 15 November 2011 and Mike Arroyo TRO Petition; in order to give tbe Arroyos an opportunity to escape prosecution and to fmstrate the ends of justice; Respondent Corona promulgated a version of tbe En Bane decision tbat is contrary to tbe manner of voting by tbe Justices; and Respondent used his votes to favor GMA and her husband to ensure tbeir speedy escape 20. Typed-written draft of Justice To show, among others, that respondent Oustice Corona rushed tbe issuance of tbe TRO Presbitero Velasco Velasco) of the 22 November against tbe DOJ on 15 November 2011 2011 Resolution on tbe GMA in order to give the Arroyos an and Mike Arroyo TRO opportunity to escape prosecution and to PetitionOustice Velasco draft); fmstrate tbe ends of justice; Respondent Corona promulgated a version of tbe En Banc decision that is contraty to the manner of voting by tbe Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape 21. Justice Antonio T. Carpio's To show, among otbers, that respondent Modifications of Justice Corona rushed the issuance of tbe TRO Velasco's draft of the 22 against the DOJ on 15 November 2011 November 2011 Resolution on 111 order to give the Arroyos an tbe GMA and Mike Arroyo TRO opportunity to escape prosecution and to Petition; of jusnce; fmstrate the ends Respondent Corona promulgated a 22. Respondent Corona's version of the En Banc decision that is handwritten corrections on contrary to tbe manner of voting by the

Justice Velasco's draft of the 22 Justices; and Respondent used his votes November 2011 Resolution on to favor GMA and her husband to the GlvIA and Mike Arroyo TRO ensure their speedy escape Petition, 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;

23. Resolution dated 22 November To show, among others, that respondent 2011 on the GMA and Mike Corona rushed the issuance of the TRO Arroyo TRO Petition; against the DOJ on 15 November 2011 ill order to glVe the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice; Respondent Corona promulgated a version of the En Banc decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedv escape To show, among others, that respondent 24. Logbook showing the date and time Justice Sereno's dissent to Corona rushed the issuance of the TRO the 22 November 2011 against the DOJ on 15 November 2011 Resolution was received by the in order to give the Arroyos an opportunity to escape prosecution and to Clerk of Court En Banc; frustrate the ends of justice; Respondent Corona promulgated a version of the En Banc decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape :25. Dissenting Opinions dated 15 To show, among others, that respondent November 2011, 18 November Corona rushed the issuance of the TRO 2011 and 13 December 2011 of against the DOJ on 15 November 2011 Justice Sereno on the GMA and ill order to glVe the Arroyos an opportunity to escape prosecution and to Mike Arroyo TRO Petition; frustrate the ends of justice; Respondent Corona promulgated a version of the En Banc decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedv escape 26. Dissenting Opinions dated 15 To show, among others, that respondent November 2011 and 13 Corona rushed the issuance of the TRO December 2011 of Justice Carpio against the DOJ on 15 November 2011 on the GMA and Mike Arroyo in order to give the Arroyos an TRO Petition; opportunity to escape prosecution and to frustrate the ends of justice; Respondent Corona promulgated a version of the En Banc decision that is contrary to the manner of voting by the Tustices; and Respondent used his votes

to favor GMA and her husband to ensure their speedy escape 27. Notes of respondent Corona of To show, among others, that respondent the 29 November 2011 Supreme Corona rushed the issuance of the TRO Court En Banc Session on the against the DOJ on 15 November 2011 GMA and Mike Arroyo TRO in order to give the Arroyos an Petition; opportunity to escape prosecution and to of justice; frustrate the ends Respondent Corona promulgated a version of the En Banc decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape 28. Agenda and Minutes of the 29 To show, among others, that respondent November 2011 Supreme Court Corona rushed the issuance of the TRO En Banc Session on the GMA against the DOJ on 15 November 2011 and Mike Arroyo TRO Petition; In order to gtve the Arroyos an opportunity to escape prosecution and to of justice; frustrate the ends Respondent Corona promulgated a version of the En Banc decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape 29. Separate Opinion dated 13 To show, among others, that respondent December 2011 of Justice Corona rushed the issuance of the TRO Velasco on the GMA and Mike against the DOJ on 15 November 2011 Arroyo TRO Petition; In order to give the Arroyos an opportunity to escape prosecution and to of justice; frustrate the ends Respondent Corona promulgated a version of the En Banc decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape 30. Concurring Opinion dated 13 To show, among others, that respondent December 20110f Justice Abad Corona rushed the issuance of the TRO on the GMA and Mike Arroyo against the DOJ on 15 November 2011 TRO Petition; In order to give the Arroyos an opportunity to escape prosecution and to of justice; frustrate the ends Respondent Corona promulgated a version of the En Bane declSlon that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape 31. Letter dated 24 November 2011 To show, among others, that respondent of Justice Carpio addressed to Corona rushed the issuance of the TRO the Chief Justice with tide: "Re: against the DOJ on 15 November 2011 GR No. 199034, Gloria In order to give the Arroyos an Macapagal Arroyo v. Hon. Leila opportunity to escape prosecution and to of justice; the ends M. De Lima" copy furnished to frustrate all Justices and the Clerk of Respondent Corona promulgated a version of the En Banc decision that is

Court.

contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape To show, among others, that respondent Corona rushed the issuance of the TRO against the DOJ on 15 November 2011 1n order to give the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice; Respondent Corona promulgated a version of the En Bane decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape

32. Memorandum dated 05 December 2011 of Clerk of Court Enriqueta E. Vidal for the Chief Justice and the Associate Justices stating that as "per instruction of Associate Justice Presbitero J. Velasco, the dissenting opinion of Associate Justice Maria Lourdes P.A. Sereno (Sereno) 1n the Resolution dated 22 November 2011 shall be taken up in the seSSlOn of the En Bane on Tuesday, December 6, 2011";

33. 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, furnished to all Justices and the Clerk of Court;

To show, among others, that respondent Corona rushed the issuance of the TRO against the DOJ on 15 November 2011 1n order to gIVe the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice; Respondent Corona promulgated a version of the En Banc decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape

34. Agenda and Minutes of the To show, among others, that respondent Supreme Court En Bane Corona rushed the issuance of the TRO Sessions dated 06 December against the DOJ on 15 November 2011 In order to give the Arroyos an 2011; opportunity to escape prosecution and to frustrate the ends of justice; Respondent Corona promulgated a version of the En Banc decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape 35. Certified True Copy of the To show, among others, that respondent decision ill "Leave Division Corona favored only Gl'vLA OCA-OAS vs. Wilma Salvacion P. Huesdens" docketed as A.M. No. P-11-2927, promulgated on 13 December 2011; .36. Certified True Copy of the To show, among others, that respondent Corona rushed the issuance of the TRO

Supreme Court Internal Rules;

against the DO] on 15 November 2011 m order to glVe the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice; Respondent Corona promulgated a version of the En Bane decision that is contrary to the manner of voting by the ] ustices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape

37. Certified True Copy of G.R. No.

To show, among others, that respondent 197930 where the Supreme Corona favored only GMA Court denied Efraim Genuino's prayer for a TRO against Watchlist Order No. 2011-422, issued under the authority of the same DO] Circular No. 41 that is the subject of the GMA and Mike Arroyo TRO Petitions;

38. Official Appointment of To show, among others, that respondent Respondent Corona as Associate Corona rushed the issuance of the TRO against the DOJ on 15 November 2011 Justice of the Supreme Court; m order to gtve the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice; and on the close personal relationship between Corona and GMA 39. Official Appointment of To show, among others, that respondent Respondent Corona as Chief Corona rushed the issuance of the TRO against the DO] on 15 November 2011 Justice; m order to give the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape

40. Official Appointment of Midas Respondent Corona distorted the Marquez as Spokesperson of the Supreme Court decision on the Supreme Court. As stated in the effectivity of the TRO in view of a clear Complaint, the Spokesperson in failure to comply with the conditions of several instances made the Supreme Court amounting to a misleading statements; betrayal of public uust; and that Respondent suppressed 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 that Respondent provided the Court spokesman with Supreme misleading information 41. Official Appointment of Justice To show, among others, that respondent Arturo D. Brion (Brion) as Corona rushed the issuance of the TRO

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Justice of the Supreme Court. Justice Brion was present in the Supreme Court En Bane Sessions and may shed light as to who drafted the Resolutions dated November 15, 2011 and November 18, 2011 on the GMA and Mike Arroyo TRO Petition;

against the DOJ on 15 November 2011 in order to gIve the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape

42. Official Appointment of Justice To show, among others, that respondent Presibetero Velasco as Justice of Corona rushed the issuance of the TRO against the DOJ on 15 November 2011 the Supreme Court. 1n order to gIVe the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape 43. Official Appointments of Justice Diosdado M. Peralta, Justice Lucas P. Bersamll, Justice Jose P. Perez, Justice Roberto A. Abad, Justice Mariano C. Del Castillo, Justice Teresita J. Leonardo de Castro, and Justice Martin S. Villarama To show, among others, that respondent Corona rushed the issuance of the TRO against the DOJ on 15 November 2011 in order to give the Arroyos an opportunity to escape prosecution and to frustrate the ends of justice; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape

44. Rollo of the cases with G.R. No. To show, among others, that respondent 199034 and 199046. Corona rushed the issuance of the TRO against the DOJ on 15 November 2011 1n order to gIve the Arroyos an opportunity to escape prosecution and to of justice; frustrate the ends Respondent Corona promulgated a version of the En Bane decision that is contrary to the manner of voting by the Justices; and Respondent used his votes to favor GMA and her husband to ensure their speedy escape

Respectfully Submitted, Quezon City for Pasay City, February 2,2012.

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HOUSE OF REPRESENTATIVES Prosecution Panel Ambrosio Padilla Hall 2nd Floor, GSIS Bldg., Financial Center, Roxas Blvd., Pasay City

By:

. NIEL C. C 'l,ressman, 511> District, Iloilo hairman, Committee on Justice Lead Prosecutor

TU~...p

Copy Furnished (By personal service): Justice Serafin R. Cuevas (Ret.) et aJ. Counsel for Respondent Chief Justice Renato Corona Suite 1902 Security Bank Centre 6776 Ayala Avenue Makati City, Philippines 1226