Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE PROVINCIAL PROSECUTOR (Sub- Office)
Dolores, Eastern Samar
PEOPLE OF THE PHILIPPINES,
Plaintiff

NPS No. VIII-13A-INV-16A-00003

For: Violation of Sec 5, R.A 9165
NPS No. VIII-13A-INV-15L-00116
For:Violation of Sec 11 and 12 R.A 9165
NPS No. VIII-13A-INV-16A-00002
For: Violation of Sec 1, R.A 8294 As
amended by Sec 28 (a) of R. A 10591

-versusCLARISSA RODELES y RONCAL

And ROLANDO MAGNO y OBINA
Respondent.
x- - - - - - - - - - - - - - - - - - - - - - - - x
MOTION TO RELEASE / WITHDRAW SEIZED ARTICLES
RESPONDENTS, by counsel, unto this Honorable Office most respectfully
aver : THAT1. This Honorable Office issued a Joint Resolution dated February 10,
2016 stating, among other, That:
Accordingly, except for the dangerous drugs that were submitted
and tested positive to contain methamphetamine hydrochloride
including the buy- bust money of two 500 pesos bills with serial
number DZ482515 and MK 347622, and the two firearms, the
magazines and all the ammunitions, all other articles seized are
hereby ordered release to the respondents for failure of the
complainant to sufficiently prove that they are utilized or used
in the commission of the crime charged against both the
respondents.
2. Wherefore premises considered, it is respectfully prayed before this
Honorable Office that said seized items be released.
Dolores Eastern Samar, May 25, 2016.

CHARLES JENSEN A. WHITE

Counsel for respondents

CONFORME:
ROLDAN GUIDO A. CAPITO
Deputy Provincial Prosecutor

COPY FURNISHED:
PS Inspector Alex Tiu Robin
Chief of Police
Dolores Municipal Police Station
Dolores, Eastern Samar