Jerramy Joson, 32, was arrested on charges of falsification of public documents.
She was arrested Wednesday morning after attending a hearing at the Angeles City Hall of Justice for a different case.
She was temporarily detained by the Pampanga CIDT but was released after she posted P12,000 bail.
Joson earlier presented a notebook that contained names of individuals who were allegedly bribed in the Maguindanao massacre case. Joson claimed the notebook belongs to Arnel Manaloto,a lawyer of the Ampatuans who are the primary accused in the Maguindanao massacre.