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Republic of the Philippines

Department of Justice
National Prosecution Service
OFFICE OF THE PROSECUTOR
Cabagan, Isabela
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Republic of the Philippines
Second Judicial Region
REGIONAL TRIAL COURT
Branch 22
Cabagan, Isabela

THE PEOPLE OF THE PHILIPPINES,


Plaintiff,

-versus- Criminal Case No. 22-3285

KRISTOFFERSON PUA y TIU


Accused.
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MOTION TO RELEASE MOTOR VEHICLE

I am respectfully requesting the release to my custody the motor


vehicle which was impounded by virtue of the filing of the above-
mentioned case and in connection therewith, I declare under oath:

1. That I am the Branch Manager of Kevin Henry Marketing


Corporation Tumauini, Isabela from which the Suzuki MC Model
registered under the name of accused Kristofferson T. Pua was
purchased. Copy of the record of payment is hereto attached
and made integral part hereof as Annex “A”.

2. That the said vehicle is more particularly described as follows,


to wit:
Make: Suzuki
Type: Motorcycle
Model: FV110LA
Color: Black/White
Plate Number: BC 56996
Chassis Number: BF464105302
Engine Number: AEP1111231

As evidenced by the certified true copies of its Certificate of


Registration and Official Receipt which are hereto attached and
made integral part hereof as Annexes “B” and “C”, respectively.

3. That at present, the above-mentioned vehicle is impounded at


and under the custody and control of the Philippine National
Police, Tumauini, Isabela by virtue of the filing of the above
case.

4. That I move for the release of the same as it is being exposed


to the elements and in so doing, might cause rust damage to
the motorcycle.

5. That truth to tell, the said motor vehicle is yet to be paid in full
by the accused and it would be for the advantage of the
company, the accused and the court if the same be released in
our custody.

Attached hereto and made integral part hereof as Annex “D” is


the Affidavit of Undertaking executed in support of this motion.

6. That I am willing to substitute the same with certified true


copies of its Certificate of Registration and Official Receipt.

7. That this motion is filed in the interest of justice.

WHEREFORE, premises considered, it is most respectfully prayed


of this Honorable Office that an Order be issued directing the Tumauini
Police Station, Tumauini, Isabela, to release the aforesaid vehicle to the
movant at the soonest possible time.

Cauayan City, Isabela. December 04, 2019

ROBERTO B. RAMONES
Movant

SUBSCRIBED AND SWORN to before me this ___ day of December,


2019 at Cauayan City, Isabela, Movant exhibiting to me his competent
proof of identity,

Doc No.
Page No. Notary Public
Book No.
Series of 2019

Copy furnished:

PHILIPPINE NATIONAL POLICE


Tumauini, Isabela
REPUBLIC OF THE PHILIPPINES )
PROVINCE OF ISABELA ) S.S.

AFFIDAVIT OF UNDERTAKING

I, ROBERTO B. RAMONES, of legal age, Filipino with office address


at District 1, Don Jose Canciller Ave., Cauayan City, Isabela, after having
been sworn in accordance with the law hereby depose and state that:

1. I am the Branch Manager of Kevin Henry Marketing Corporation


Tumauini, Isabela from which the Suzuki MC Model registered
under the name of accused Kristofferson T. Pua was purchased;
2. Sometime last July 27, 2016, Kristofferson T. Pua, the driver and
owner of the vehicle, was involved in an incident as per Criminal
Case Number 22-3285 of the Philippine National Police, Tumauini,
Police Station. Copy of the Certification is hereto attached as
Annex “A”
3. Because of such incident and by virtue of the information filed
against Kristofferson T. Pua before the RTC Cabagan, the vehicle
that he was driving was impounded by the Tumauini Police
Station, Tumauini, Isabela;
4. I hereby undertake to produce said vehicle upon request of the
Honorable Office of the Prosecutor and/or the Honorable Court
where the case against the accused has been filed if such will be
needed for further proceedings or investigation.
5. This affidavit is being executed to support my request for the
release of the impounded vehicle;
6. I am executing this undertaking to attest to the truth of the
foregoing.

IN WITNESS WHEREFORE, I have hereunto set my hands this


______ day of December 2019 in Cauayan City, Isabela, Philippines.

ROBERTO B. RAMONES
Movant

SUBSCRIBED AND SWORN TO before me this _____ day of


December, 2019 in the City of Cauayan, Isabela, Philippines, Movant
exhibiting to me his competent proof of identity.

Doc No.
Page No. Notary Public
Book No.
Series of 2019

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