REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

_______________________
__________________
_______________________

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- CRIMINAL CASE NO. ______

_____________________________
Accused.
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MOTION TO RELEASE MOTOR VEHICLE

Accused, through the undersigned counsel and unto the Honorable

Court, most respectfully avers that:

1. Records show that the above-captioned case has already been decided
by the Honorable Court. The decision convicting the accused and
sentencing him to suffer a penalty of five (5) years to six (6) years
imprisonment and to pay a fine amounting to six thousand pesos (Php
6,000.00) was promulgated on March 7, 2018

2. The motorcycle and the sidecar attached to it, which form part of the
prosecution’s evidence, up to this day, remains in the custody of the
Philippine National Police (PNP), _____________;

3. The abovementioned motorcycle is registered under the name of the

accused and is more particularly described as follows:

MAKE: HONDA

TYPE: MOTORCYCLE

CHASIS NO: ___________

ENGINE NO: ____________

MV FILE NO: _____________

4. The actual owner of the of the motorcycle and the sidecar described
above is the sister of the accused, ___________________. It is the
latter who pays for the monthly amortization of the motorcycle;
 PRAYER

WHEREFORE, premises considered, it is respectfully prayed of the

Honorable Court that the motorcycle described above and the sidecar attached
to it be RELEASED to ______________________.

Other reliefs, just and equitable, are likewise prayed for.

_________________, March 20, 2018.

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