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Department of Justice
OFFICE OF THE PROVINCIAL PROSECUTOR
Malolos, Bulacan
COMES NOW, movant MELCY CUBOS MENDOZA, unto this Honorable Office,
most respectfully alleges that:
MAKE Honda
MV FILE NO. 0301-00000794999
DENOMINATION Motorcycle without sidecar
ENGINE NO. JA46E1017429
CHASSIS NO. MH1JA4611JK019892
YEAR MODEL 2018
2. Attached herewith are the copies of the Official Receipt and the Certificate of
Registration as Annex “A” and “B”, respectively.
3. The above described motor vehicle was taken and presently in the custody of
the arresting members of the Philippine National Police stationed at Bocaue
Police Station, Poblacion, Bocaue, Bulacan where it has been impounded
since 01 November 2018.
4. Said motor vehicle is not liable for any offence and within the lawful
commerce of men, therefore cannot be confiscated or forfeited by the
government.
“xxx
Such proceeds and instruments or tools shall be
confiscated and forfeited in favor of the government,
unless they be the property of a third person not
liable for the offense x x x “
8. The detention and impounding of the said vehicle would cause irreparable
damages to the owner and a violation of her constitutional right to due
process of law as it constitutes deprivation of property without due process
of law and taking without legal authority. Hence, there is an urgent necessity
for the immediate release of the said motor vehicle belonging to herein
movant MELCY CUBOS MENDOZA.
PRAYER
Other reliefs just and equitable in the premises are also respectfully prayed for.
Gapan City, Nueva Ecija for Malolos, Bulacan City, 21 February 2019.
Copy furnished: