Lawyer Melanio "Batas" Mauricio Jr., in his letter, also informed the justice department that he has asked police authorities to launch a manhunt for primary witness Wensis Tablang.
Abellas husband, Raul, has been trying to reach Tablang in his given addresses in Cubao, Quezon City and Camarin, Caloocan, but to no avail, Mauricio added.
Tablang served as driver and bodyguard to businesswoman Marybeth Lopez de Leon, who is suspected to have shot Abella dead inside her luxury car last month.
De Leon, wife of Jose Vicente Madrigal de Leon, and a resident of Ayala-Alabang Village, Muntinlupa, has denied the accusation in a counter-affidavit submitted to Las Piñas City state prosecutor Mario Mangrobang.
Mauricio said Raul, son Jansen, Tablang, and another witness, subidivision security Conrado Erasca, should be placed under the WPP to "assure their safety and presence when this case is already prosecuted in court."
The lawyer said Raul has received reports that Tablang "could have gone into hiding for fear of his life considering alleged threats against him, or because he has been asked to make himself scarce so he could no longer testify in the case, which could lead to its dismissal."
Mauricio has filed a manifestation on Tablangs reported diseappearance before the city prosecutors office.
In the sworn statement he gave the police hours after the incident, Tablang said he saw De Leon alight from her BMW sedan holding a Glock-type 9-mm pistol in front of BF International Village.
Erasca was said to have seen Tablang wrestle the gun away from the suspect, who drove off after her driver pulled a bleeding Abella from the backseat of the car and rushed her to a nearby hospital where she expired.
De Leons lawyers later turned over the car to the Criminal Investigation and Detection Group (CIDG) in Camp Crame, Quezon City. Nikko Dizon