REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
VALENCIA CITY

DARYL T. ROLLORATA, NPS DOC. NO. X-13-INQ-

18C-00045
Complainant,
-versus-
RUBELYN G. SANTILLAN
Respondent.
x---------------------------------------------X

MOTION TO RELEASE MOTOR VEHICLE

Comes Now, movant DARYL T. ROLLORATA, through the undersigned

counsel and unto this Honorable Office, most respectfully state that:

Movant is the absolute and registered owner of a Pick-up with Plate No.
AAG4774, and more particularly described as follows, to wit:
Make: Mitsubishi
Series: STRADA GLX 2.5D
Engine No: 4D56UAB8639
Chassis No: MMBJNKK300FH004199

as evidenced by the photocopy of the Official Receipt and Certificate of

Registration hereto attached as Annexes “A” and “A-1” hereof, respectively;

That the above motor vehicle is presently impounded at the Highway

Patrol Group, Valencia City, Bukidnon, 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 his day to day activities and continued impounding of said
vehicle, needless to state, would further caused its deterioration beyond repair.

This motion is filed in the interest of justice;

WHEREFORE, it is most respectfully prayed unto this Honorable Office

that an Order be issue directing the turn over of the said motor vehicle to the
complainant or his representative.
Reliefs and other remedies equitable, just and proper in the premises are
likewise prayed for.

March 3, 2018. Malaybalay City, Bukidnon.

LAGAMON AND ASSOCIATES LAW OFFICE

2nd Floor, Jamstar Bldg., corner
Judge Carillo-San Isidro St.
Brgy 5 Poblacion, Malaybalay City Bukidnon
Counsel for the Complainant Daryl T. Rollorata
 By:

DENCE CRIS L. RONDON

Roll of Attorneys’ No. 67495
PTR No. 6933714/10-JAN-2018/BUK.
IBP O.R. No. 23742/15-JAN-2018/BUK.
Tax Identification No. 496-556-017-000
Exempted from compliance with MCLE for the year 2018