REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 58, MANILA

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - CRIM. CASE NO.874851

FOR: Violation of Section 11
Article II of RA 9165
ABS,
Accused.
x ----------------------------------------- x

MOTION FOR RELEASE OF MOTOR VEHICLE

COMES NOW, movant JUAN DELA CRUZ, assisted by the Public Attorney’s
Office through the undersigned public attorney, unto this Honorable Court most
respectfully states that:

1. First and foremost, the accused vehemently and vigorously denies the charges
imputed against him;

2. That at the time the accused was apprehended by the police officers, he was on
board a motorcycle and that when he was brought to the police station, the motor
vehicle was also taken to the said police station;

3. That the motor vehicle, up to now, is still in the possession of the police
operatives at WPD Police Station 7, located at Jose Abad Santos, Tondo, Manila,
said motor cycle is more particularly described as follows:

Make:
Engine Number:
Chassis Number:
Plate Number:

4. That as proof of ownership over the said vehicle, movant JERRY GAN presented
the Certificate of Registration and the Official receipt over said vehicle, copies of
which are hereto attached as ANNEX-A and ANNEX-B respectively;

5. That petitioner most humbly and respectfully prays that the motor vehicle be
released and that the possession of which be returned to him being the registered
owner thereof.

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

Court that the foregoing motion be granted, ordering the WPD Police Station 7 to
release the vehicle to the movant JUAN DELA CRUZ

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

Manila, Philippines. December 16, 2004.

 JUAN DELA CRUZ

Movant

Assisted by:
Department of Justice
PUBLIC ATTORNEY’S OFFICE
Manila District Office
4 Floor W. Godino Bldg.
th

350 Arroceros Street

Ermita, Manila

By:
ATTY. MAE B. AURA

NOTICE OF HEARING

The Branch Clerk of Court

RTC, Branch 16-Manila

ACP CHRISTIAN LIM

Office of the City Prosecutor
Manila

Greetings:

Please submit the foregoing Motion for the kind consideration and approval of the
Honorable Court on January 17, 2005 at 8:30 in the morning.

ATTY. MAE B. AURA

Copy furnished:

ACP CHRISTIAN LIM

Office of the City Prosecutor
Manila

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 17, MANILA
PEOPLE OF THE PHILIPPINES,
Plaintiff,

- versus - CRIM. CASE NO. 05-237243

FOR: Robbery in band
Bienvenido Barizo y Alfonso, Sr.
And Carlito Amor y Nicolas,
Accused.
x ----------------------------------------- x

MOTION FOR RECONSIDERATION

COMES NOW, movant JOSEFINA C. AMOR, assisted by the Public

Attorney’s Office through the undersigned public attorney, unto this Honorable Court
most respectfully states that:

1.That on February 16, the Honorable Court issued an order denying the
motion to release vehicle filed by movant Josefina C. Amor ;

2. Herein movant Josefina Amor most respectfully moves for a

reconsideration of the said order on the ground that it is not a community
property of accused Carlito Amor and herein seeks to clarify her position;

3.Herein movant Josefina Amor is the sister-in-law of accused Carlito Amor .

She is married to Ceferino Amor, the brother of Carlito Amor and attached hereto is their
marriage contract to prove said fact;

4 .Herein movant Josefina Amor, who is not a party to this case, is the owner of a
motor vehicle more particularly described as follows:

Make: Toyota
Engine Number:2C-3017824
Chassis Number:CF50-0015965
Plate Number:XRJ249

That as proof of ownership over the said vehicle, movant JOSEFINA C.

AMOR presented the Certificate of Registration and the Official receipt over said
vehicle, copies of which are already attached as ANNEX-A and ANNEX-B respectively
in the motion to release vehicle;

5. That the motor vehicle, up to now, is still in the possession of the police operatives
at the Police Anti-crime Emergency Response, located at Camp Bagong Diwa, Bicutan,
Taguig, Metro Manila;

6. That in lieu of the physical possession of the said vehicle herein movant prays the
photographs of subject vehicle, the certificate of registration and official receipt already
submitted and the affidavit of undertaking be deemed sufficient so that herein registered
owner who is not a party to this case may continue to use the vehicle, which has now
deteriorated;

7. That even without the physical possession of the vehicle the prosecution can still
proceed with its case as the said vehicle is not an essential element in the crime of
robbery in band;
 8. That MOVANT most humbly and respectfully prays that the motor vehicle be
released as it is also their source of livelihood and they have already suffered so much
when the said vehicle was seized and being the registered owner, she has absolutely no
participation nor personal knowledge of this case nor is a party to the case.

9. That attached hereto is the affidavit of undertaking of movant Josefina Amor that
she shall bring the said motor vehicle at any time the Court orders that it be brought to
Court;

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

Honorable Court that the order denying the motion to release vehicle be reconsidered and
that an order be issued for the POLICE ANTI-CRIME EMERGENCY RESPONSE
to release the vehicle to the movant and registered owner JOSEFINA C. AMOR, who is
not a party to this case.

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

Manila, Philippines. February 17, 2006.

JOSEFINA C. AMOR
Movant

Assisted by:
Department of Justice
PUBLIC ATTORNEY’S OFFICE
Manila District Office
4 Floor W. Godino Bldg.
th

350 Arroceros Street

Ermita, Manila

By:
ATTY. MINERVA A. BAUTISTA

NOTICE OF HEARING

The Branch Clerk of Court

RTC, Branch 16-Manila

ACP DOMINGO ORDA JR.

Office of the City Prosecutor
Manila
Greetings:

Please submit the foregoing Motion for the kind consideration and approval of the
Honorable Court on March 2 , 2006 at 8:30 in the morning.

ATTY. MINERVA A. BAUTISTA

Copy furnished:

ACP Domingo Orda Jr.

Office of the City Prosecutor
Manila