REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
ANGELES CITY

CHRISTINE MAE PELAEZ y VERNA, NPS DOC. NO. INQ-16E-00375

Complainant,
-versus-
EDWARD REYES y SANTOS,
JASPER GARCIA y VITAL &
GLEN CURA y LARA
Respondent.
x---------------------------------------------X
MOTION TO RELEASE MOTOR VEHICLE

Comes Now, movant RACHELLE JOY SANTOS REYES, unto this Honorable Court,
most respectfully state that:

Movant is the absolute and registered owner of a Tricycle with Plate No. ____________,
and more particularly described as follows, to wit:
Make: Mitsukoshi
Series: Daan Hari
Engine No: 161 FMJE 2312165
Chassis No: ________________

as evidenced by the O. R and C.R hereto attached as Annezes A and B hereof;

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

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

That movant is willing to substitute the same with a 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.

Angeles City, May 16, 2016.

RACHELLE JOY SANTOS REYES

Complainant