Motion to Release Impounded Vehicle

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

MUNICIPAL TRIAL COURT IN CITIES
CEBU CITY
BRANCH 61

PEOPLE OF THE PHILIPPINES,

vs. Crim. Case No. 123456

  For: RECKLESS IMPRUDENCE

  RESULTING IN SERIOUS PHY. INJURIES

AKU SADO,

Accused,

X----------------------------------------X

MOTION TO RELEASE IMPOUNDED VEHICLE 

COMES NOW, movant JUAN DELA CRUZ, by himself, unto this Honorable Court,
respectfully states that:

1.  Movant with residential address at 1234 Colon Street, Cebu City, is the registered
owner of Isuzu dump truck with Plate No. KLD-456 as evidenced by Official Receipt
and Certificate of Registration issued by the Land Transportation Office, copies of which are
hereto attached as Annexes "A" and "A-1";

2.  The said vehicle was involved in a vehicular accident on August 3, 2019 at 4:00 in
the afternoon in Barangay Kalubihan, Cebu City, causing physical injury to one Pedro
Santos;
 3.   That said vehicle was impounded and currently under the custody of Kalubihan
Police Station;

4.   The said vehicle is being utilized by the movant in his business and was never
intended to be used for any illegal purpose;

5.   The continued impounding of the said vehicle has impaired the movant's capacity
to earn and would further cause the vehicle's deterioration;

6.   Movant will ensure the delivery of the above described motor vehicle to the
Honorable Court when needed in the course of the proceedings;

7.   Movant shall endeavor to attend all succeeding hearings in the above-captioned

case. If movant anticipates that he may not be able to appear for just and valid reasons, he
shall immediately inform this Honorable Court;

8.   This motion is not intended to delay the proceedings of this case but solely for the
reasons stated above.

WHEREFORE, it is respectfully prayed that an Order be issued for the release of the
above described motor vehicle from the custody of the Cebu City Police Station Traffic
Investigation Unit and deliver the same to movant.

Other just and equitable remedies are likewise prayed for.

               (place)                ,          (date)       .

JUAN DELA CRUZ

Movant

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Municipal Trial Court in Cities, Branch 61
Cebu City

PROSECUTOR MARIEN ROVERA

Office of the City Prosecutor, Cebu City
    
ATTY. AB CD
Private Prosecutor
2233 Colon Street, Cebu City

ATTY. QR YZ
Counsel for the Accused
Wilson Street, Lahug, Cebu City

Please be notified that the undersigned will submit the foregoing motion for the
consideration and approval of the Court on _________________ at ______________.

               (place)              ,          (date)       .

JUAN DELA CRUZ

Movant

Copy furnished by personal service:

PROSECUTOR MARIEN ROVERA

Office of the City Prosecutor, Cebu City

ATTY. AB CD
Private Prosecutor
2233 Colon Street, Cebu City

ATTY. QR YZ
Counsel for the Accused
Wilson Street, Lahug, Cebu City