Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR
Bauang, La Union

JANE DOH, NPS NO.

Complainant, I-02B-INQ-18A-00031

versus for

PEPITO LANGIT, Reckless Imprudence

Respondent. Resulting in Homicide
x----------------------x

MOTION FOR THE RELEASE OF TRICYCLE

COMES NOW, the undersigned Movant, Juan Dela Cruz, and unto this Honorable Office, most
respectfully states:

1. That Movant is of legal age, married, Filipino citizen and a resident of Barangay Natividad,
Naguilian, La Union;

2. That he is the registered owner of the honda motorcycle with sidecar with Plate no. xxxxxxx as
evidenced by the Official Receipt and Certificate of Registration (OR-CR) of said vehicle,
photocopies of which are hereto attached and marked as Annexes “A” and “A-1” respectively;

3. That said vehicle is a motorized tricycle and a public vehicle and a source of income of
movant’s family;

4. That said vehicle is driven by herein respondent, Pepito Langit, as its authorized driver;

5. That movant admits that the vehicle is the same motorized tricycle involved in the instant case
pending before the Office of the Prosecutor;

6. That movant commits and undertake to present said vehicle before this Office and/or to the
Courts for identification purposes whenever so required, an affidavit of undertaking is hereto
attached and marked as “Annex “B” and forms an integral part hereof;
 7. That for the meantime, while preliminary investigation is on-going, movant most respectfully
request that the said vehicle be released to him by this Office;

8. That movant undertakes to abide with all the conditions that may be imposed by this Office or
the Courts for the release of said vehicle.

WHEREFORE, premises considered, it is most respectfully prayed that an order of release of the
subject vehicle be issued by this Honorable Office.

Other reliefs just and equitable under the premises are likewise being prayed for.

Naguilian for Bauang, La Union, February 6, 2018.

JUAN DELA CRUZ

Movant