Republic of the Philippines

Ninth Judicial Region

Regional Trial Court
Branch VI
Dipolog City

PEOPLE OF THE PHILIPPINES,

Petitioner,

- versus - Criminal Case No. 77077

FOR: Murder with Homicide

BLACK PANTHER & BUCKY BARNS,

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, BLACK PANTHER 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 prosecution’s 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 Procedure.
 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 BLACK PANTHER 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 prosecution’s evidence.

Other just and equitable reliefs are likewise prayed for.

RESPECTFULLY SUBMITTED.

City of Dipolog, October 07, 2020.

ATTY. BLACK WIDOW

Dipolog City 
Appointment No. 1234
Until December 31, 2020
Roll no. 123456 
PTR no. 1234, 1/1/20, Dipolog City 
IBP no.1234, 1/2/20, Dipolog City 
Office Address: Cruz Bldg. Dipolog City
Email: blackwidowlaw@gmail.com
Contact Number: +639171668148

NOTIFICATION AND COPY FURNISHED:

HAWK EYE
City Prosecutor
City of Dipolog
Zamboanga del Norte

The Branch Clerk of Court

RTC Branch 6
City of Dipolog
Zamboanga del Norte

Greetings!

Please submit the foregoing for the consideration and resolution of the
Honorable Court immediately upon receipt hereof.

ATTY. BLACK WIDOW

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. BLACK WIDOW

COPY FURNISHED:

HAWK EYE
City Prosecutor
City of Dipolog
Zamboanga del Norte