Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR
Bayombong, Nueva Vizcaya

DICKFRED ABUBO y ANDRES,

NPS Doc. No. II-07-INV-23C-
Complainant,
11066
FOR: RIR in Damage to Property
-versus-

JERWIN PLANAS y TUGUINAY.

Respondent.
X------------------------------------------------X

MOTION TO RELEASE VEHICLE WITH UNDERTAKING

COMES NOW, MOVANT/OWNER, LUIS I. BULLONG JR., and unto

this Honorable Office of the Provincial Prosecutor most respectfully states:

1. That the motor vehicle without sidecar with Make: MITSUKOSHI, Body
Type: Motorcycle, MV File No. 0201-00001223461, Engine No.
161FMJM1208426 and Chassis No. LF3PCK501MB814462, registered in the
name of JOMAR PASCUA CORPUZ, however, by virtue of Certificate of
Assumption issued by Ms. April Claire P. Rival, Branch Manager of Mitsukoshi
Motors, Bambang, Branch, the said motorcycle was assumed and owned by
herein MOVANT/OWNER, a copy of which is hereto attached as ANNEX “A”;

2. That the movant prays for the benevolence of the Honorable

Prosecutor to release said vehicle from the custody of Kasibu Police Station
due to the above-captioned case against accused JERWIN T. PLANAS filed
before the Office of the Provincial Prosecutor, Bayombong, Nueva Vizcaya;

3. It is therefore respectfully prayed that said vehicle be released to the

movant, considering that the movant only lends his motorcycle to the
Respondent;

4. It is further prayed unto the Honorable Prosecutor to release said

vehicle, to avoid forestall destruction, dilapidation and deterioration of said
vehicle after presentation of his proof of ownership.

5. I am submitting copies of the Certificate of Registration, Official

Receipt, and the Affidavit of Undertaking executed by the undersigned to the
effect that should the Court require the production or that the vehicle be
presented in Court, the same will be done.

WHEREFORE, premises considered it is most respectfully prayed unto

this Honorable Office of the Provincial Prosecutor that an order be issued
directing Kasibu Police Station to release the above-described vehicle in
favor of the movant/owner.

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 Other relief just and equitable under the premises is likewise prayed
for.

Kasibu, Nueva Vizcaya for Bayombong, Nueva Vizcaya, July 10, 2023.

LUIS I. BULLONG JR.

Movant/Owner

NOTICE

The Receiving Clerk

OFFICE OF THE PROVINCIAL PROSECUTOR
Bayombong, Nueva Vizcaya

GREETINGS:

Please take notice that the undersigned will submit the foregoing
motion for release of vehicle to the kind consideration and approval of the
Honorable Prosecutor immediately upon receipt hereof.

Thank you.

LUIS I. BULLONG JR.

Copy furnished:

PNP-KASIBU
Barangay Poblacion, Kasibu, Nueva Vizcaya

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REPUBLIC OF THE PHILIPPINES )
PROVINCE OF NUEVA VIZCAYA )S.S.
MUNICIPALITY OF KASIBU )

AFFIDAVIT OF UNDERTAKING

I, LUIS I. BULLONG JR., of legal age, Filipino and resident of

Barangay Poblacion, Kasibu, Nueva Vizcaya, after having been duly sworn to
in accordance with law, do hereby depose and say that:

1. I am the owner of the Motorcycle and the unit describe as follows:

Make: MITSUKOSHI/EURO
MV File No: 0201-00001223461
Engine No: 161FMJM1208626
Denomination: Motorcycle without Side Car
Chassis No: LF3PCK501MB814462
OR No: 2138753514
CR No: 42761948-5

2. The said vehicle is in the custody of PNP-Kasibu due to a case of

Dickred Abubo y Andres versus Jerwin Planas y Tuguinay with the case
number NPS Docket No. II-07-INV-23C-11066 for RIR in Damage to
Property, presently pending before the Office of the Provincial Prosecutor,
Bayombong, Nueva Vizcaya;

3. I undertake to produce the said vehicle whenever the Court requires

during proceedings of the above-mentioned case;

4. I am executing this affidavit to attest to the truthfulness of the

foregoing facts for legal intents and purposes.

IN WITNESS WHEREOF, I have hereunto set my hand this 10th day

of July 2023 at Kasibu, Nueva Vizcaya.

LUIS I. BULLONG JR.

Affiant/ Movant
Driver’s License ID No. B15-22-301067

SUBSCRIBED AND SWORN to before me, this 10th day of July 2023
at Kasibu, Nueva Vizcaya. Affiant executing to me his competent evidence of
identity as indicated below his name.

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