Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
Dumaguete City, Negros Oriental
-oOo-

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - CRIM.CASE NO. __________

For: Violation of Anti-Fencing Law
of 1979 (P.D. 1612)
ALEXANDER GUSTE Y ERAMIS
Accused.
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MOTION TO RELEASE IMPOUNDED VEHICLE

MOVANT, KHARL GIBRAN BORJA LATAZA unto to his Honorable Office,

respectfully avers that:

1. The MOVANT is the registered owner of a Mitsubishi Montero Sport Sterling Silver
Metallic with Temp Plate No. NN7264 under Cert. of Registration No. 267297634.
which impounded by reason of its involvement in the above-entitled cases for
“Violation of Anti-Fencing Law of 1979 (P.D. 1612)” filed against Mr.
ALEXANDER GUSTE Y ERAMIS, copies of the Certificate of Registration,
Official Receipt No. 1242808243, Affidavit of Undertaking, and pictures of the said
vehicle, are hereto attached;

2. That the above- mentioned vehicle was impounded at the PNP-HPG Team Negros
Oriental, Barangay Daro, Capitol Area, Dumaguete City.

3. That, the release of said vehicle would not in any way affect nor hamper if a case
against the owner and/ or the driver would be filed;

4. That the said vehicle is being used as a means of livelihood, so much so that to
deprive him of its possession would tantamount of depriving him of his family of his
right to live;

5. That herein movant hereby binds himself to produce the vehicle, if release, whenever
required by your good office or by any court of law.

WHEREFORE PREMISES CONSIDERED it is most respectfully prayed that the motion

to release impounded vehicle be granted.

Other relief is likewise prayed for.

February 28, 2019.

KHARL GIBRAN BORJA LATAZA

Movant