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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
QUEZON CITY, BRANCH 83

PEOPLE OF THE PHILIPPINES,

- versus - CRIM. CASE NO.

R-QZN-16-13726-CR

STEPHEN GATSBY MARQUEZ

Y MOLINA,
Accused.
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REITERATIVE MOTION
FOR RELEASE OF MOTOR VEHICLE

ACCUSED, by counsel and to this Honorable Court,

respectfully avers:

1. An Urgent Motion for the Immediate Release of

Evidence (Utility Vehicle) was filed by the accused on January
12, 2017, but the same has been unacted upon because of the
confinement of the accused in a center for his treatment and
rehabilitation.

2. The accused has completed and satisfactorily

complied with the requirements of Article VIII of RA 9165 on
the program for the treatment and rehabilitation of drug
dependents, per this Honorable Court’s Order dated November
20, 2018.

3. The accused now respectfully reiterates his motion for

the release of his motor vehicle subject of his earlier Urgent
Motion for the Immediate Release of Evidence (Utility Vehicle)
dated January 12, 2017, which is a Toyota Yaris with motor
vehicle plate number ZNV 473 under Motor Vehicle Certificate
of Registration (CR) No. 190660805 issued on 04/01/2014,
and the Official Receipt No. 907402521 dated 05/04/2016 by
the Land Transportation Office (LTO).
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WHEREFORE, it is respectfully prayed of this Honorable

Court that an Order be issued directing the Quezon City
(QCPD) Station 10, EDSA cor. Kamuning, Quezon City, or any
police officer/office in custody thereof, to release the vehicle
of the accused upon presentation of the Motor Vehicle
Certificate of Registration (CR) No. 190660805 issued on
04/01/2014, and the Official Receipt No. 907402521 dated
05/04/2016 by the Land Transportation Office (LTO) and the
pertinent Order of this Honorable Court.

RESPECTFULLY SUBMITTED.

Pasig City for Quezon City; January 24, 2019.

RAUL IBAY TOLENTINO

Counsel for Accused
2604-A, 26th Flr., East Tower, Phil. Stock Exch. Center
Exchange Road, Ortigas Center, Pasig City
Attorney Roll No. 37376
IBP No. 025485; January 11, 2018; RSM
PTR NO. 7045255; January 16, 2018; Manila
MCLE Compliance No. V-0019554; April 13, 2016
NOTICE

ASST. CITY PROSECUTOR ARNEL PABELLAR

Trial/Public Prosecutor

Greetings:

Please take notice that the undersigned shall submit the

foregoing motion for the consideration and resolution of the
Honorable Court on February 8, 2019 at 8:30 o’clock in the
morning.

RAUL I. TOLENTINO

THE BRANCH CLERK OF COURT

RTC Quezon City Branch 83
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Greetings:

Kindly include the foregoing in the calendar of the

Honorable Court on February 8, 2019 at 8:30 o’clock in the
morning.

RAUL I. TOLENTINO