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Urgent Motion for Case Resolution

The document is a motion filed by counsel for the respondents Roan Santos and Eddie De Alagdon Jr. requesting an early resolution in a criminal case. The respondents were arrested on July 20, 2020 on charges including human trafficking, child pornography, child abuse, and cybercrime. They have been detained since without an information being filed in court or a release order. The motion asks the prosecutor to render a resolution in the case based on the evidence presented to avoid violating the respondents' constitutional rights against unreasonable seizure while in detention.

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Andrew Belgica
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375 views2 pages

Urgent Motion for Case Resolution

The document is a motion filed by counsel for the respondents Roan Santos and Eddie De Alagdon Jr. requesting an early resolution in a criminal case. The respondents were arrested on July 20, 2020 on charges including human trafficking, child pornography, child abuse, and cybercrime. They have been detained since without an information being filed in court or a release order. The motion asks the prosecutor to render a resolution in the case based on the evidence presented to avoid violating the respondents' constitutional rights against unreasonable seizure while in detention.

Uploaded by

Andrew Belgica
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
  • Introduction: The introduction provides the case details including docket number, parties involved, and the nature of the motion.
  • Motion Details: Describes the motion's basis, referencing relevant laws and the request for urgent resolution.
  • Conclusion: Concludes the motion with formalities, including listing the law office representing the respondents and contact details.

Republic of the Philippines

Department of Justice
OFFICE OF THE PROSECUTOR GENERAL
Padre Faura, Manila

ANTI-HUMAN TRAFFICKING DIVISION


Operatives (NBI Manila),
Complainant,
-versus- NPS DOCKET NO. XVI-INQ-20G-00051

ROAN SANTOS and EDDIE DE ALAGDON JR.,


Respondents.

x - - - - - - - - - - - - - - - - - - - - - - - - -x
URGENT MOTION FOR EARLY RESOLUTION

Respondents, by counsel, to the Honorable Prosecutor, respectfully states that:


1. This is a criminal action for alleged violation of the following:
a. R.A. 9208, otherwise known as the Anti-Trafficking in Persons Act of 2003, as
amended by R.A. No. 10364 for the charge of Frustrated Murder and has been behind
bars since his arrest on August 1, 2013;
b. R.A. No. 9775, otherwise known as the Anti-Child Pornography Act of 2009;
c. R.A. No. 7610, otherwise known as the Anti-Child Abuse Law;
d. R.A. 10175, otherwise known as the Cybercrime Prevention Act of 2012.
2. Respondents were arrested without warrant on July 20, 2020 at their residence in Tramo,
Bacoor Cavite.
3. Respondents had undergone the necessary inquest proceedings on July 21, 2020, conducted by
Assistant State Prosecutor Jeannette Dacpano.
3. Respondents have been patiently waiting for the inquest resolution while in detention. To this
date, no information has been filed in court nor a release order issued in favor of the respondents.
4. Thus, the undersigned is requesting the early resolution of the above-entitled case to avoid
violation of the constitutional rights of the resondents against unreasonable seizure.

WHEREFORE, it is respectfully prayed that a Resolution be rendered in this case based


on the evidence presented.
Other just and equitable reliefs are likewise prayed for.
Parañaque City, 10 September 2020.

BELGICA LAW OFFICE


Counsel for the Respondents
17A Sta. Lucia St., San Antonio Ave,
San Antonio Parañaque City

by:

ANDREW A. BELGICA
17-A, Sta. Lucia St., cor. San Antonio Ave., SAV-1,
Brgy. San Antonio, Parañaque City
Attorney Roll No. 74499
MCLE Compliance No.(Newly Admitted to the Bar)
PTR No. 2414615 / July 7, 2020- Parañaque CityTax
IBP No. 125653, 07/22/2020
Tax Identification No. 306-394-603
Email: atty.andrewbelgica@gmail.com
Tel No.: 85142413, Mobile No. : 09185763952

Copy furnished:

JEANNETTE M. DACPANO
ASSISTANT STATE PROSECUTOR
Padre Faura, Manila

Republic of the Philippines Department of Justice OFFICE OF THE PROSECUTOR GENERAL Padre Faura, Manila ANTI-HUMAN TRAFFICKING
Parañaque City, 10 September 2020. BELGICA LAW OFFICE Counsel for the Respondents 17A Sta. Lucia St., San Antonio Ave, S

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