Republic of the Philippines

REGIONAL TRIAL COURT

Region III
Branch 16, City of San Fernando

PEOPLE OF THE PHILIPPINES,
Plaintiff,

- versus - Criminal Case No. 969-31


Brutus Bottom,
Accused,
x ---------------------------------------------- x

MOTION FOR THE PRODUCTION AND INSPECTION OF DOCUMENTS


Accused, through undersigned counsel, to this most Honorable Court, respectfully states that:

1.At the last hearing held last February 14, 2013, the undersigned private counsel repeated its
request to the prosecution to provide the former with certified copies of the affidavits of the
complainant as well as the photographs taken by the arresting officers of the Center Turn Police
District;
2.That up to present time, no copies were furnished to the accused or his undersigned
counsel;
3.That said copies are urgently needed in order to prevent unnecessary alteration and
suppression of records on the part of the prosecution and;
4. To justifiably allow the defense to sufficiently prepare its counter-allegations against the
said complainant.
5. This motion is made pursuant to Section 10 of Rule 116 of the 1997 Revised Rules of Criminal
Procedure.

















PRAYER

WHEREFORE, the foregoing premises thoroughly considered, in the interest of substantial
justice, it is most respectfully prayed that an Order for the Production and Inspection of Documents be
issued, requiring the Hon. Prosecutor Hap Chan;
1) to furnish the counsel for the accused all the records, affidavits and photographs related in the
abovementioned case.

Other just and equitable reliefs are likewise humbly prayed for.

City of San Fernando, March 2, 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 take notice that the foregoing Motion shall be submitted for the consideration and
resolution of the Honorable Court on 5 March 2013 at 10:45 A.M., or as soon as counsel and matter
may be heard.

Atty. Rommelito Francisco E. Macarayo













EXPLANATION

The foregoing Motion 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