Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Third Judicial Region
Cabanatuan City Branch 3
Province of Nueva Ecija

PEOPLE OF THE PHILIPPINES,

Plaintiff,

Crim. Case No. 98734

For: Reckless Imprudence
Resulting in Homicide and
Damage to Property
-versus-

REY RAMILO y PEÑAREDONDA,

Accused.
X - - - - - - - - - - - - - - - - - - - - - - - - - -X

MOTION TO RESOLVE CASE

The ACCUSED, unto the Honorable Court, respectfully moves to
resolve the above-captioned case in view of the following premises, to wit:
1. A Motion to Release Vehicle with Affidavit of Undertaking dated
August 31, 2022 was filed before this Honorable Court on the same day
August 31, 2022 by the undersigned movant.
2. According to the Order of this Honorable Court dated October 4,
2022, “The counsel for the private complainant shall submit a comment on
the motion to release vehicle filed by the accused within ten days from
today, further ensuring that it bears the conformity of the public
prosecutor."
 3. Despite lapse of time, the Plaintiff, as per verification, has yet to
comment on said motion.
4. However, up to this date, no Comment has been made by the
private complainant and this Honorable Court has yet to decide on this
filed Motion to Release Vehicle with Affidavit of Undertaking .
5. In view of the above, so as not to prejudice the rights of the owner
of the vehicle, it is humbly requested that the instant motion be granted.

PRAYER

WHEREFORE, in light of the foregoing, complainant most

respectfully prays of the Honorable Court to grant the foregoing motion
and accordingly resolve the case in favor of accused-movant.
Other reliefs just and equitable in the premises are likewise prayed
for.

October 21, 2022, City of San Jose del Monte for Cabanatuan
City, Nueva Ecija.
By:

REY P. RAMILO
Accused

Copy furnished:

LEX VIRTUS LAW FIRM

For the Private Complainant
2nd Floor Insular Life Bldg. Rizal St.,
Brgy. Matadero, Cabanatuan City
 NOTICE OF HEARING AND EXPLANATION

Greetings!

Please take notice that we are submitting this Motion for approval of
the Honorable Court on Friday, October 28, 2022 at 8:30 in the morning.

A copy of this Motion was served via registered mail to Lex Virtus
Law Firm due to distance, lack of time and law office personnel to effect
personal delivery.

REY P. RAMILO