00:00For context, Your Honours, the prosecution filed a request for admission to narrow the matters genuinely in dispute, conserve the
00:07Honorable Court's valuable time for issues that truly require evidence and resolution, and ensure that the proceedings are conducted fairly
00:15and efficiently for the benefit of all the parties.
00:18Inihain po namin ang request for admission upang maging mas maayos at mabilis ang paglilitis po nitong kaso. Ito lang
00:26po ang aming layunin na tukuyin kung alin ang tunay na pinagtatalunan nang hindi na kailangan ubusin ang oras ng
00:34hukuman sa mga bagay na maaari namang kilalanin o hindi naman talaga kontrobersyal.
00:40The request covers certain self-evident and factual matters, including records produced and submitted directly by several banks in compliance
00:50with the subpoenas issued by this court.
00:53Among others, the respondent was simply requested to admit or deny the existence, genuineness, and authenticity of these bank records.
01:02On September 23, 2026, the respondent filed her objection. She principally argues that Rule 26 is supposedly inapplicable to impeachment
01:13proceedings, that requiring her to answer would supposedly violate her right against self-incrimination and improperly shift the burden of
01:22proof,
01:22and that certain requested matters allegedly implicate marital or filial privileges, are irrelevant, or fall outside the relevant period.
01:33With the Honorable Court's permission, the prosecution will briefly explain why the objection should be overruled and how resolving this
01:40matter may substantially streamline and shorten the presentation of evidence and conserve the valuable time of this Honorable Court.
01:48Your Honours, with due respect, none of the grounds raised by the respondent justifies the wholesale rejection of the prosecution's
01:57request for admission.
01:58First, the respondent argues that Rule 26 is inapplicable because impeachment proceedings are penal in character.
02:06But an impeachment trial, Your Honours, is neither an ordinary civil action nor a criminal prosecution.
02:12It is, as we have repeatedly said, a sui generis constitutional proceeding governed principally by the rules of the Senate
02:20sitting as an impeachment court.
02:22Where those rules do not specifically provide otherwise, the rules of court may be applied supletorily, subject always to the
02:30control and discretion of this court.
02:52The request for admission is not being invoked to alter the burden of proof or to compel the respondent to
02:58establish the prosecution's case and will not have that effect.
03:02Its purpose is simply to narrow the issue and avoid the needless presentation of witnesses and evidence on matters that
03:09are not genuinely disputed.
03:12Ang mga bank records na tinukoy po namin sa request for admission ay galing mismo sa mga banko at idiniretso
03:19sa hukumang ito.
03:20Hindi po ito dumaan sa kamay ng prosekusyon.
03:23To be clear, the respondent has not made any claim that they are fake or fabricated.
03:29Ang nagsubmit nitong records ay hindi po mga pipitsugi na banko.
03:32These are known banks who would not submit fake documents to this court.
03:37They know how important this case is.
03:40They know the whole nation is watching.
03:43Nakataya ang kanilang pangalan at reputasyon dito.
03:46That is why we are saying that the authenticity of the bank documents is not genuinely disputed.
03:52Second, the request does not violate the respondent's rights against self-incrimination.
03:57It does not require her to take the witness stand, give an oral confession, or create evidence that is not
04:04already available to the parties and to this court.
04:07More importantly, most of the requested matters concern only the existence and authenticity of documents already produced by independent banks
04:17in compliance with the order or subpoena issued by this court.
04:20Indeed, the request merely seeks recognition of existing records, does not compel the respondent to generate new testimonial or documentary
04:30evidence against herself.
04:33The respondent relies on authorities involving an accused in a criminal prosecution.
04:37These rulings, we submit, should not be mechanically extended to this sui generis proceeding,
04:43particularly with respect to neutral and disputable matters that do not, by themselves, establish liability or culpability.
04:52Wala pong paglabag sa karapatan ng respondent labag sa self-incrimination, your honest please.
04:58Hindi po namin siya pinapaamin sa anumang kasalanan o pananagutan.
05:02Ang hinihingi lang po namin ay ang pagkilala sa mga dokumentong sinamit mismo ng mga banko,
05:08pursuant to the subpoenas of this court, sa mga bagay na hindi naman tunay na pinagtatalo namin.
05:15Third, the request does not shift the burden of proof.
05:18An admission merely dispenses with proof of a matter that is no longer genuinely disputed.
05:24It has absolutely no effect on who has the burden of proof.
05:28Ang purpose lamang po ng aming request ay wag nang pag-aksayahan ng oras ng hukuman
05:33ang mga bagay na hindi naman kailangan patunayan pa.
05:36Fourth, the marital and filial privileges cited by the respondent do not justify striking out the entire request.
05:45Those privileges generally concern the compelled testimony of one spouse against the other
05:50or of a person against a parent or child.
05:53Here, the prosecution is not compelling the respondent to testify against her spouse, parent or child.
06:00At most, any claim of privilege, if legitimate, should be considered in relation to the particular matter affected.
06:08It is not a basis for expunging the prosecution's request in its entirety.
06:13Hindi po nagiging privilege ang isang dokumento dahil lamang nabanggit dito ang asawa, magulang o anak ng respondent.
06:21Hindi po natin pinipilit ang respondent na tumistigo sa kanya asawa.
06:25At kung meron mang particular na paksa na saklaw talaga ng privilege,
06:29yun lamang ang dapat tukuyin at resolbahan.
06:32Hindi po dapat ibasura ang buong request for admission dahil lang doon.
06:36Fifth, the respondent's generalized objections based on relevance, remoteness or the periods covered by the records
06:44cannot justify the wholesale rejection of the request.
06:47At the very least, this Honorable Court has already determined that there was sufficient basis to require the banks
06:54to produce these records through its compulsory process.
06:58Finally, Your Honours, the request is not a belated attempt to cure a deficiency in the prosecution's evidence.
07:04Again, the bank's records were produced during these proceedings pursuant to sub-Pinas.
07:11Once the records became available, the prosecution properly sought to narrow the issues surrounding them
07:16and avoid consuming the court's time by presenting numerous witnesses
07:21simply to establish matters that should not reasonably be disputed.
07:26Hindi po ito afterthought, Your Honours.
07:28Gaya ng nasabi ko kanina, inihain po ang request ng maging available ang mga dokumentong sinabmit ng mga bangko
07:34alinsunod sa sub-Pinas ng hukuman.
07:37Ang layunin po ay simple, tukuyin kung alinang tunay na pinagtatalunan
07:42at huwag nang ubusin ang panahon at oras ng korte sa pagpapatawag ng maraming witnesses
07:47para lamang patunayan ng mga bagay na hindi naman genuinely disputed.
07:53Your Honour, for these reasons, the prosecution respectfully submits that the objection should be overruled
07:59and that the matters covered by the request should be deemed admitted pursuant to Rule 26 of the Rules of
08:05Court.
08:06But, Your Honour, please, nevertheless, in the spirit of cooperation,
08:11and to avoid unnecessary delay or disagreement, the prosecution has a proposal or proposition for the respondent.
08:20In their objection, the respondent claims, and I quote,
08:24if indeed, this is from paragraph 41 for the record,
08:28quote, if indeed their intent was to shorten the proceedings,
08:31the prosecution has itself repeatedly utilized stipulations to dispense with the presentation of matters
08:37that are not genuinely disputed.
08:40If speed were truly the objective, the same course remained available.
08:46Since, according to the respondent, the same course remains available,
08:50we are willing to enter into stipulations with the respondent in relation to the bank documents,
08:55as well as other documents produced by witnesses through the subpoenas issued by this court.
09:01These stipulations will be limited only to three basic matters.
09:05Number one, that the bank records exist.
09:08Number two, that they were produced by the identified banks pursuant to subpoenas issued by this Honourable Court.
09:15And number three, that they are genuine and authentic copies of the records maintained and produced by those banks.
09:22Ganun lang po kasimple, Your Honours.
09:24We will withdraw our request for admission if the respondent will agree to this.
09:29The proposed stipulations would not require the respondent to admit liability,
09:34the truth or accuracy of every entry, or the prosecution's interpretation of any transaction.
09:39The respondent would remain free to contest the relevance, meaning, evidentiary weight, and legal effect of the records.
09:48Kung makapagkasundoan po tayo to the defense, we would be able to dispense with about at least 10 to 20
09:58witnesses
09:59who would be testifying on the same things anyway.
10:03Kung iaharapan natin ang humigit-kumulang dalawampung karagdagang testigo para lang patunayan ng mga foundational matters na ito,
10:11malaking bahagi ng oras ng mga pagdinig ang masasayang sa mga bagay na hindi naman tunay na pinagtatalun.
10:18In conclusion, Your Honours, the respondent herself expressly declared that stipulations remain available.
10:25The prosecution is prepared to take the respondent at her word.
10:30Therefore, we invite the respondent to engage in stipulations on these matters
10:36so that we can proceed with the actual litigation that must be done in this case.
10:41Maraming salamat po.
10:54You
