REPUBLIC OF THE PHILIPPINES )

PROVINCE OF DAVAO ORIENTAL)SS.

CITY OF MATI )
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AFFIDAVIT OF UNDERTAKING

I, MICHELLE T. CASTILLON, of legal age, Filipino, single and a resident of Purok Cara-
2, Brgy. Central, Mati City, Davao Oriental, Philippines, after having been duly sworn to in
accordance with law, hereby depose and say, THAT:

I am the owner of a motor vehicle a Honda Motorcycle with Engine No.

KWY00E046828, Chassis No. KWY0046822 and bearing Plate No. 3111LG as evidenced by a
Certificate of Registration No. 8791095-5 issued by the Land Transportation Office, Mati
District Office, Mati City, Davao Oriental;

On November 1, 2012 said motor vehicle was impounded and placed under the
custody of the Mati City Police Station, Mati City, Davao Oriental when it was recovered
from Christopher Taranza who carnapped it when he was arrested by responding
policemen of the Mati City Police Force on a follow up operation conducted by the said
police officers;

The respondent Christopher Taranza was held for questioning and documentation
and eventually a charge for Violation of RA 6539 otherwise known as Anti-Carnapping Law
was filed against said respondent with the Sub-Provincial Prosecution Office, Mati City,
Davao Oriental;

Until present, my motor vehicle remained under the custody of the Mati City Police
Station, Mati City, Davao Oriental;

Considering that said vehicle is needed as my service vehicle in going to my place of

work at St. Peter Funeral Homes, I am requesting for the release of said motor vehicle from
the custody of the Mati City Police Force as the same was carnapped from her and besides,
same is not used in any illegal activity;

As the registered and lawful owner of said vehicle, I undertake to present said
motor vehicle should the Public Prosecutor or the Trial Court require me to do so and will
not hesitate to present the same;

I am executing this affidavit to attest to the truth of the foregoing facts and for
whatever legal purpose it may serve.

IN WITNESS WHEREOF, I have hereunto set my hand 8th day of January, 2013 at City
of Mati, Davao Oriental, Philippines.

MICHELLE T. CASTILLON
Affiant

SUBSCRIBED AND SWORN to before me this 8th day of January, 2013 at City of Mati,
Davao Oriental, Philippines. I hereby certify that I have personally examined the affiant
and that I am satisfied that she voluntarily executed and understood the foregoing
statement.
 Republic of the Philippines
Department of Justice
NATIONAL PROSECUTION SERVICE
SUB- PROVINCIAL PROSECUTION OFFICE
Mati City, Davao Oriental

MICHELLE T. CASTILLON,
Plaintiff, NPS XI-10-INV. 12L-0196

- versus - FOR: VIOL. OF RA 6539

CHRISTOPHER TARANZA,
Respondent.
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MOTION TO RELEASE MOTOR VEHICLE

COMES NOW, MOVANT MICHELLE T. CASTILLON, to this Honorable Office,

respectfully states, THAT:

Movant is the owner of a motor vehicle a Honda Motorcycle with Engine No.
KWY00E046828, Chassis No. KWY0046822 and bearing Plate No. 3111LG as evidenced by a
Certification of Registration No. . 8791095-5 issued in her favor by the Land Transportation
Office, copy of which is hereto attached Annex “A” forming part of this motion;

Said vehicle was impounded and now in the custody of the Mati City Police Station,
Mati City, Davao Oriental after it was recovered from the respondent when the latter was
arrested by the Mati City Police operatives during the follow up operation conducted by
said agency after I reported the carnapping incident with the Mati City Police Station, Mati
City, Davao Oriental.

A charge for Violation of RA 6539 otherwise known as the Anti-Carnapping Law was
filed against the respondent Christopher Taranza and is now pending with the Sub-
Provincial Prosecution Office of Mati City, Davao Oriental. Meantime, movant’s motor
vehicle was not yet released to her and has been impounded at Mati City Police Station
since November 1, 2012.

Considering that said vehicle is needed as movant’s service vehicle in going to her
place of work at St. Peter Funeral Homes, movant is now requesting for the release of said
motor vehicle from the custody of the Mati City Police Force as the same was just
carnapped from her, is not used in any illegal activity and since its continued
impoundment would only cause damage to the said vehicle.

Movant is willing to produce the said unit should the Honorable Court or this Office
require the same. Attached is the affidavit of undertaking of the herein owner, to form
part of this motion.

WHEREFORE, premises considered, it is prayed of this Honorable Office that this

motion be granted by releasing the afore-described motor vehicle bearing Plate No.
3111LG to herein movant.

City of Mati, Davao Oriental, Philippines, January 8, 2013.

MICHELLE T. CASTILLON
Complainant/Movant