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Republic of the Philippines REGIONAL TRIAL COURT Region III Branch 16, City of San Fernando PEOPLE OF THE

PHILIPPINES, Petitioner, - versus TREVOR BELMONT & RICHTER BELMONT, Accused, x ---------------------------------------------- x URGENT MOTION FOR DISCHARGE OF ACCUSED TO BE A STATE WITNESS The People, through the undersigned prosecutor, unto this Honorable Court, respectfully states: 1. That after a careful, thorough, and meticulous perusal and examination of all the records and evidences on hand, the undersigned believes that the testimony of accused, Trevor Belmont is indispensable and absolutely necessary to strengthen the case of the prosecution; 2. That there is no other direct evidence available except for the testimony of the mentioned accused; 3. That said testimony is vital to bolster the prosecutions claim and can be substantially corroborated with the evidence of the prosecution as shown in the records; 4. That said accused is merely an accomplice and therefore, not the most guilty. 5. This motion is made pursuant to Section 17 of Rule 119 of the 1997 Revised Rules of Criminal Criminal Case No. 77077 FOR: Murder with Homicide


PRAYER WHEREFORE, the foregoing premises considered, in the highest interest of substantial justice, it is respectfully prayed that the foregoing Motion for Discharge of an Accused to be a State Witness be granted, requiring: 1) Discharging TREVOR BELMONT from being an accused in the abovementioned criminal case to being a State Witness in behalf of the Prosecution, and; 2) To admit his testimonies as part of the prosecutions evidence. Other just and equitable reliefs are likewise prayed for. RESPECTFULLY SUBMITTED. City of San Fernando, May 19, 2013. (Sgd.) Atty. Rommelito Francisco E. Macarayo Counsel for the Accused 13-69 Barracks Building, Marikina IBP NO. 87123-7/19/12-AC PTR NO. 669913/21/12-AC Roll No. 99998 MCLE Exempt (Admitted to the bar: April 6, 2012) NOTIFICATION AND COPY FURNISHED: ANTONIO ANTONIO L. SANTOS City Prosecutor City of San Fernando Pampanga The Branch Clerk of Court RTC Branch 16 City of San Fernando Pampanga Greetings! Please submit the foregoing for the consideration and resolution of the Honorable Court immediately upon receipt hereof. Atty. Rommelito Francisco E. Macarayo

EXPLANATION The foregoing Urgent Motion to Discharge an Accused to be a State Witness is being filed with this Honorable Court and served on the opposing counsel by registered mail in view of the impracticability of personal filing and service due to distance considering that the office of this Honorable Court is at the City of San Fernando, while undersigned counsel holds office in Marikina. Atty. Rommelito Francisco E. Macarayo

COPY FURNISHED: Atty. Antonio Antonio L. Santos City Prosecutor City of San Fernando Pampanga