REPUBLIC OF THE PHILIPPINES Congress of the Philippines Senate SITTING AS THE IMPEACHMENT TRIBUNAL tary FEG-? Pal IN THE MATTER OF THE IMPEACHMENT OF RENATO C. CORONA AS CHIEF JUSTICE OF fPoog THE SUPREME COURT OF THE PHILIPPINES. Case No. 002-2011 REPRESENTATIVES NIEL Cc. TUPAS, JR. (other complainants comprising at least one third (1/3) of the total Members of the House or Representatives as are indicated below.) = REQUEST FOR ISSUANCE OF SUBPOENA Duces Tecum In relation to the instant impeachment proceedings, The HOUSE OF REPRESENATIVES respectfully requests for the issuance of subpoena duces tecum requiring GING REYES, head of the ABS-CBN News and Current Affairs Division, or the designated official custodian of the documents or videos stated hereunder with office address at: ABS-CBN Broadcast Center, Sgt. Esguerra Ave. corner Mother Ignacia St., Barangay Laging Handa, Diliman, Quezon City, Philippines, to bring on February 9, 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, the following: 1. Video of the Press briefing of Supreme Court Midas Marquez on 15 November 2011 at around 1:30 pm wherein he made the announcement that: (a) the Supreme Court, through an 8-5 ruling, decided to issue a Temporary Restraining Order [TRO] in favor of Gloria Macapagal Arroyo [GMA] in connection with her inclusion in the watch-list order {WLO] of the DOJ, (b) that among those who voted for said issuance is Chief Justice Renato C. Corona, (c) that after compliance with the 2 conditions imposed in the TRO, to wit: posting of bond and submission by GMA of SPA, GMA may already leave the country, (d) that Midas Marquez admitted during said press briefing that the Supreme Court was still drafting the resolution as of said time;2. Video showing Atty. Ferdinand Topacio preparing for the payment of cash bond on 15 November 2011 at around 5:00 pm to 7:00 pm; 3. Video showing the posting / payment of cash bond at the Supreme Court made by GMA, through her representative, on 15 November 2011 at around 6:00 pm, in relation to the TRO issued by the ‘Supreme Court in her favor; 4, Video showing the attempted travel of Former President Gloria Macapagal Arroyo (GMA) on 15 November 2011 from the time she left the hospital to the time she arrived at the airport; 5. Video showing the arrest of GMA by virtue of a warrant of arrest issued by Judge Jesus Mupas of Branch 112 of the Regional Trial Court of Pasay Ci 6. Video showing the statement of Midas Marquez on November 16, 2011 in Head Start stating that the TRO is still in full force and effect; 7. Video showing the statements of Midas Marquez in reaction to the allegations that he made untruthful statements regarding the TRO issued in favor of GMA made on November 20, 2011; 8. List of cameramen who covered said incidents as above-stated; Said documents and videos are being required for the purpose of proving, 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) That statements were made by the Public Information Office of the Supreme Court relating to the TRO; (5) That SC spokesperson Midas Marquez announced to the media (through a press conference) the 8-5 ruling in favor of a TRO against Arroyo's WLO, though said resolution was still being drafted; (6) The manner 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) The allegations contained in the Verified Complaint, and other pleadings filed by complainants, and other matters relevant to the instant case.Respectfully Submitted, Pasay City, February 7, 2012. HOUSE OF REPRESENTATIVES Prosecution Panel Ambrosio Padilla Hall 2" Floor, GSIS Bldg., Financial Center Roxas Blvd., Pasay City By: Ss IN. NIEL C. TUPAS; 4, Coygressman, 5" District, Iloil Chfirman, Committee on Justice Lead Prosecutor Copy furnished (By personal service) Peceivecl in bebalf of fre dafenwe: Justice Serafin R. Cuevas (Ret.) et al. _——, Counsel for Respondent Chief Justice Renato Corona . Copa a 1d . Suite 1902 Security Bank Centre biancerd io 6776 Ayala Avenue oper if Makati City, Philippines 1226 ty, Philippi 4q:2cpm