Motion To Release Motor Vehicle

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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE PROVINCIAL PROSECUTOR
TUGUEGARAO CITY, CAGAYAN

HILAERO SACOBO, NPS DOC. NO. II-INQ-17H-00132


Complainant,
-versus-

JOEL; DANAO y FURUGGANAN


Respondent.
x---------------------------------------------X
MOTION TO RELEASE MOTOR VEHICLE

Comes Now, movant, unto this Honorable Court, most respectfully state that:

Movant is the absolute and registered owner of a MOTORCYCLE with pre-assigned


Plate No.BF14868 and more particularly described as follows, to wit:
Make: HONDA
Series: XRM
Engine No: KPY00E113057
Chassis No: KPY00113054

as evidenced by the Certification from Honda Motorista Tuguegarao Branch, O. R and


C.R hereto attached as Annex “A”, “B” and “C” hereof;

That the above motor vehicle is presently impounded at the Alcala Police Station by
virtue of the filing of the above case;

The movant moves for the release of the same as he is using the same as his personal
service in her day to day activities;

That movant is willing to substitute the same with an Affidavit of undertaking and
photocopy of its Certificate of Registration and Official Receipt, together with a copy of its
photographs;

This motion is filed in the interest of justice;

WHEREFORE, it is most respectfully prayed unto this Honorable Office that the
foregoing motion be granted.

Tuguegarao City, August 17, 2016.


JOEL DANAO y FURUGGANAN
Complainant

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