No. He didn't. Juan may not know about this. It certainly has become very relevant now.
I think JM knows all there is know about JA and her dirty tricks, and waaaay more than we do. Her Helio text lie is part of a larger pattern of intercepts and redirects that JM has known about before the guilt phase even got underway.
The difference now is how much more is being allowed in. Must in one way be an embarrassment of riches for JM. So much to choose from to use against her. He's an incredibly effective editor of evidence, and has narrowed down to just handfuls of pieces; all incredibly damning and revealing.

