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.

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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