REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
CAW CITY, BRANCH xx

PEOPLE OF THE PHILIPPINES,

-versus- CRIM. CASE NO.

R-PSY-17-xxx-CR
R-PSY-15-xxx-CR
R-PSY-19-xxx-CR

Juan Dela CRUZ et, al.

Accused.
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MOTION TO RELEASE
MOTOR VECHICLE and
other Personal Properties
Accused and the intervenor Juan Del Cruz, through the
undersigned counsel, and unto this Honorable COURT, a most respectfully
moves and avers the following:

1. The accused had file at least two motions to release impounded

vehicle, money, and other properties for lack of merit.

2. In the Formal Offer of Evidence of the prosecution, it appears that

they did not offer motor vehicle with ]. It Attached here certified true
copy of the Certificate of Registration and the Official Receipt as
ANNEX “A.”

3. The movant Cruz also executed an affidavit of undertaking regarding

the motor vehicle. Attached here as ANNEX “B.”

4. We also move the released of the cellphones, driver licenses, and

sixteen thousand eight hundred pesos 1 in different denomination
that allegedly seized from the accused.

5. It must be noted that prosecution did not include this on their pre-
trial nor being identified by the prosecution witnesses particularly

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 John . It was not also part of the evidence that was formally offered
by the prosecution.

6. Again, the motor vehicle and other properties seized by the Loc is
necessary for his autn daily life and subsistence of their family.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of

the Honorable COURT that issue Order directing the xyz to release the
following:

Other relief and remedies, just and equitable under the

circumstances, are likewise prayed for.

Pasay City, 3 December 10922.

NOTICE

The Honorable
Cleark of Court

G r e e t i n g s!

Immediately upon receipt hereof, please submit the foregoing motion

for the consideration and approval of the Honorable COURT.

Copy furnished:

Office of the Prosecutor

Pasay City

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