REPUBLIC OF THE PHILIPPINES
SENATE OF THE PHILIPPINES
[Sitting as an Impeachment Court]
Pasay CITy, METRO MANILA
PHILIPPINES
In re Impeachment Trial of Impeachment Case No. 002-2011
Honorable Chief Justice
Renato C. Corona
Philippine Airlines, Inc.
MANIFESTATION AND MOTION
(re Subpoena Ad Testificandum et Duces Tecum)
Philippine Airlines (PAL), through the undersigned counsel, and unto this Honorable
Impeachment Court, most respectfully files the Manifestation with respect to the subpoena ad
testificandum et duce tecum (the “Subpoena”) issued by the Honorable Impeachment Court:
L.
The Subpoena directs Mr. Enrique P. Javier, Vice President — Sales, and Ms. Ria Carrion
Domingo, Vice President — Product Loyalty Marketing to bring before the Senate of the
Philippines original and certified true copies of the documents listed therein at 10:00
o'clock in the morning on the 9" day of February 2012. The Subpoena likewise requires
the said persons to thereafter appear before the Senate of the Philippines at 2:00 o’clock
in the afternoon on the 9" day of February 2012 and everyday thereafter until the purpose
of the Subpoena shall have been fulfilled.
PAL manifests that the Subpoena was served on it only on 09:40 in the morning of
February 09, 2012. As a result, PAL has not had adequate prior notice required to collect
and collate the documents required to be presented under the Subpoena on which Mr.
Javier and Ms. Domingo will be required to testify.
Given the foregoing, PAL hereby requests that it be given adequate time by this
Honorable Impeachment Court to collect and collate the documents required to be
produced under the Subpoena.
PAL does not in any way intend to delay the prosecution of this case considering the
outmost importance of these proceedings.Inte impeachment ‘Tra of Honorable Chie Justice Corona
PRAYER
WHEREFORE, it is respectfully prayed that the Honorable Impeachment Court grant
Philippine Airlines, Inc. such period as the Honorable Impeachment Court may deem to be
adequate to permit Philippine Airlines, Inc. to produce the documents required under the
‘Subpoena dated 09 February 2012.
Done in Pasay City, for Pasay City, this 09" day of February 2012.
PHILIPPINE AIRLINES, INC.
LEGAL AFFAIRS DEPARTMENT
8" Floor, PNB Financial Center,
Diosdado Macapagal Avenue,
CCP Complex, Pasay City 1300
By.
MA. CLARA C, DE CASTRO
“AVP-LEGAL AFFAIRS
IBP No, 8¥6952/28DEC1 I/Bacuto Ciry
PTR No. 2637257/06JANI12/Pasay CITY
ROLL oF Attys. No.: 44477
MCLE Cert No. II1-0004608
HOUSE PROSECUTION PANEL