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Republic of the Philippines Congress of the Philippines Senate REPUBLIC OF THE PHILIPPINES CONGRESS OF THE PHILIPPINES SENATE SITTING AS THE IMPEACHMENT COURT IN THE MATTER OF THE IMPEACHMENT OF RENATO C. CORONA AS CHIEF JUSTICE OF THE SUPREME COURT OF THE PHILIPPINES, CASE NO. 002-2011 REPRESENTATIVES NIEL C. TUPAS, JR., JOSEPH EMILIO A. ABAYA, LORENZO R. TAÑADA, III, REYNALDO V. UMALI, ARLENE J. BAG-AO (other complainants comprising one third (1/3) of the total Members of the House of Representatives as are indicated below.) x -------------------------------------------------------------------------------------------------------- x COMPLIANCE The HOUSE OF REPRESENTATIVES, through its PROSECUTORS, respectfully submits the instant Compliance to the Order1 of the Honorable Tribunal rendered on 24 January 2012 requiring the Prosecutors to submit 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 1 TSN, January 24, 2012, p. 7. The Order rendered by the Honorable Tribunal required both parties to submit, within three (3) days, a written list of the names of the witnesses and the substance of their testimonies, as well as a list of the documentary exhibits. 2 This list presumes that the defense will not be willing to stipulate on the documents subject matter of the witnesses’ testimonies. 2 ARTICLE I List of Witnesses 1. Mr. Marianito Dimaandal, Head, Records Office, Office of the President, Malacañang, Manila - He will identify CJ Corona’s Service Records with then Vice President and later President, Gloria Macapagal Arroyo, and testify in relation thereto. 2. Atty. Enriqueta Vidal, Clerk of Court, Supreme Court – She will identify CJ Corona’s Service Records as Associate Justice and later as Chief Justice of the Supreme Court, and testify in relation thereto. 3. Prof. Harry Roque, Director, U.P. Law Center, Diliman, Quezon City - He will testify as an expert witness on the voting record of CJ Corona as a Member of the Supreme Court to prove his partiality and subservience to former President Gloria M. Arroyo, both when she was President and later after she ceased to be one. 4. Undersecretary Jose Luis C. Gascon, Malacañang, Manila - He will testify as a Member of the 1986 Constitutional Commission that drafted the present Constitution on the origin, backgroud and rationale for the midnight appointments ban under Article VII, Sec. 15 of the Constitution and on Betrayal of Public Trust as an impeachable offense under Article XI, Sec. 2 of the Constitution. 5. Ms. Donna Z. Pazzibugan, Philippine Daily Inquirer, Chino Roces Avenue corner Yague and Mascardo Streets, Makati City. - As a Malacañang accredited reporter for the PDI, she will testify and prove that during the oath-taking of CJ Corona in Malacañang Palace on May 17, 2010 the public and even the accredited media were barred. 6. Ms. Emma Rey, Executive Director, Congressional Library Bureau, House of Representatives, Batasan Hills, Quezon City - She will identify certain parts of the Records of the 1986 Constitutional Commission and testify in relation thereto. Documentary Evidence A. With reference to the testimony of Mr. Marianito Dimaandal 3 1. Certified true copies of the Service Records of CJ Corona as Chief of Staff and Spokesperson of then Vice President Gloria M. Arroyo, and later as Chief of Staff and Spokesperson of then President Gloria M. Arroyo as well as Acting Executive Secretary of then President Gloria M. Arroyo. B. With reference to the testimony of Atty. Enriqueta Vidal 1. Certified true copies of the Service Records of CJ Corona as Associate Justice (April 9, 2002 to May 16, 2010) and as Chief Justice (May 17, 2010 to present). C. With reference to the testimony of Prof. Harry Roque 1. Chart/table showing the voting pattern of the respondent as a Member of the Supreme Court. D. With reference to the testimony of Undersecretary Jose Luis C. Gascon 1. Certified photocopies of portions of the Records of the Constitutional Commission. E. With reference to the testimony of Ms. Donna Z. Pazzibugan 1. PDI issue of May 18, 2010 F. With reference to the testimony of Ms. Emma Rey 1. Certified photocopies of portions of the Records of the Constitutional Commission. ARTICLE II List of Witnesses 1. Register of Deeds of Makati City - He will testify on the Condominium Certificate of Title and Deed of Absolute Sale pertaining to condominium unit purchased by Renato C. Corona and Cristina R. Corona in The Columns Ayala Avenue. 2. Mr. Giovanni Ng, Finance Director/representative of Megaworld Corp. - He will testify on the purchase of Renato Corona and Cristina Corona of a penthouse (with three 4 parking slots) at The Bellagio Condominium, and of a lot at McKinley Hill Village, as well as on the circumstances and particulars of said sale transactions. 3. Mr. Aniceto Visnar, Jr., representative of Ayala Land - He will testify on the purchase of Renato C. Corona and Cristina R. Corona of the Bonifacio Ridge condominium unit. 4. Ms. Nerissa H. Josef, representative of Community Innovations, Inc. - She will testify on the purchase of Renato C. Corona and Cristina R. Corona of The Columns condominium unit. 5. Mr. Greg Gregonia, representative of Burgundy Realty Corporation - He will testify on the purchase of Renato C. Corona and Cristina R. Corona of Burgundy Katipunan condominium unit. 6. Records Officer of John Hay Management Corp. - He/she will testify on the SALN filed, if any, by Cristina R. Corona at the John Hay Management Corp. 7. Representative of National Statistics Office (NSO) - He/she will testify on the Certificate of Live Birth of Ma. Carla R. Corona-Castillo and Ma. Charina R. Corona and the Marriage Certificate/Contract of Ma. Carla R. Corona-Castillo and Constantino Castillo III. 8. Director, Corporate Registration and Monitoring Dept. of SEC - He/she will testify on the SEC records of Basa-Guidote Enterprises, Inc. 9. Representative of Housing Land Use Regulatory Board - He/she will testify on the records on file of the following projects: The Bellagio, Bonifacio Ridge, Mckinley Hill and Burgundy Plaza Katipunan. 10. 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. 5 12. Ms. Ava Venus A. Mejia, Vice President - Finance, Filinvest Alabang, Inc. - She will testify on the execution of the Deed of Sale of Common Share between Filinvest Alabang, Inc. and Spouses Renato C. Corona and Cristina R. Corona notarized on September 11, 2009 covering one (1) common share of the The Palms Country Club, Inc. 13. Certified Fraud Examiner (CFE) - He/she will render expert opinion on the true or correct Net Worth of Renato C. Corona and his incapacity to acquire the properties registered under his name and that of his wife and children based on his declared income. Documentary Evidence A. With reference to The Columns property to be testified to by The Register of Deeds of Makati City and Nerissa J. Josef 1. Condominium Certificate of Title No. 85716 in the name of Cristina R. Corona; 2. Deed of Absolute Sale between Community Innovations, Inc. and Cristina R. Corona dated October 1, 2004; 3. Buyer’s Information Sheet; 4. Contract To Sell; 5. Various Official Receipts; and 6. Deed of Absolute Sale. B. With reference to The Bellagio and McKinley property to be testified to by Giovanni Ng 1. Deeds of Absolute Sale pertaining to the purchase of The Bellagio unit and Mckinley Hill lot; 2. Contract to Buy and Sell; 3. Request for Reservation and Offer to Purchase; 4. Various Official Receipts; 5. Deed of Assignment; 6 6. Letter-request dated September 8, 2004; and 7. Buyer’s Information Sheet. C. With reference to the Bonifacio Ridge property to be testified to by Aniceto Visnar Jr. 1. Buyer’s Information Sheet; 2. Various Official Receipts; 3. Deed of Absolute Sale; and 4. Certificate Authorizing Registration and Documentary Stamp Tax Declaration. D. With reference to the Burgundy property to be testified to be Greg Gregonia 1. Reservation Application; 2. Contract To Sell; 3. Statement of Account with Various Official Receipts; 4. 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 7 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.
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