NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT

Branch 99, Manila

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - CRIM. CASE NO. 78542565

For: Reckless Imprudence
Res. To Serious Physical Injuries and
Homicide
REYNA AMIHAN.,
Accused.
x ------------------------------------------------ x

ACCUSED REYNA AMIHAN., assisted by the Public Attorney’s Office, thru

the undersigned Public Attorney, unto this Honorable Court most respectfully avers that:

MOTION TO RELEASE VEHICLE

ACCUSED REYNA AMIHAN., assisted by the Public Attorney’s Office, thru

the undersigned Public Attorney, unto this Honorable Court most respectfully avers that:

1. Accused was charged for the crime of reckless imprudence resulting to homicide
and is pending before the Honorable Court;

2. That the registered owner of PICK UP with plate no. ABCX-12365447 is KING
ARTHUR and attached herewith as ANNEX “A” is the photocopy of certificate
of registration of the said vehicle and as ANNEX “B” the Photocopy of the
Official receipt;

3. That the accused is being appointed as the duly authorized representative of

QUEEN B, the registered owner of the vehicle which is the subject matter of the
above-entitled case, and attached hereto as ANNEX “C” is the special power of
attorney made in favor herein accused;

4. That the said motor vehicle is now in the control and possession of the Western
District Traffic Enforcement Office, Atlanta Street, Port Area, Manila;

5. That this motion has been made in order to prevent any damage and dilapidation
of the said motor vehicle due to the fact the place where the said motor vehicle is
parked is surrounded by squatters;

6. Accused humbly and most respectfully moves that an Order be issued releasing
the PICK UP with plate no. ABCX-12365447 to herein accused.

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court that the foregoing motion be granted in the interest of justice and on
humane considerations.

Other reliefs just and equitable under the premises are likewise prayed for.
 Manila, Philippines. March 28, 2007.

Department of Justice
PUBLIC ATTORNEY’S OFFICE
Manila District Office
4th Floor W. Godino Bldg.
350 Arroceros Street
Ermita, Manila

By:

ATTY. _________________

NOTICE OF HEARING
(Copy furnished To:)
MARY DEL
The Branch Clerk of Court
MTC, Branch 25, Manila

ACP FGSDG
Office of the City Prosecutor
Manila

Greetings:

Please submit the foregoing Motion for the kind consideration and approval of the
Honorable Court on March 30, 2007 at 8:30 in the morning or immediately upon
receipt hereof.

ATTY. _________________

Copy furnished:

ACP FGSDG
Office of the City Prosecutor
Manila