Republic of the Philippines

REGIONAL TRIAL COURT

Second Judicial Region
Branch 36
Santiago City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- CRIM CASE NO. 11109

For: Violation of Section 5, 11 Article
II of Republic Act 9165

MELVIN GARCIA y ASIS,

Accused.
x- - - - - - - - - - - - - - - - - - - - - x

MOTION TO RELEASE
MOTOR VEHICLE
Comes Now, movant DENNIS B. FRAGATA, unto this
Honorable Court, most respectfully state that:

Movant is the absolute and registered owner of a

motorcycle with sidecar with Plate No. __________ and more
particularly described as follows, to wit:

Make: RUSI
Series: TC125
Engine No: RROTC125E0006026
Chassis No: RROTC123E0006026

That the above motorcycle with sidecar is presently

impounded at the Police Regional Office 2, Camp Adduru,
Tuguegarao City, Cagayan, by virtue of the filing of the above-
entitled case;

That the aforesaid motorcycle with sidecar is needed for

our daily transportation. Hence, there is a need for its release
from custody. Rest assured that the same vehicle shall be
presented to the competent authorities when required
evidenced by the undersigned’s Affidavit of Undertaking;[1]

1 Annex “A”;

1
 That the Certificate of Registration,[2] Official
Receipt[3] and three (3) pictures[4] of the aforementioned
motor vehicle are hereto attached for purposes of
identification;

This motion is filed in the interest of justice;

WHEREFORE, it is most respectfully prayed unto this

Honorable Court that the foregoing motion be granted.

Other relief and remedy that is deemed just and

equitable under the circumstances is being prayed for.

Santiago City, 22 September 2017.

DENNIS B. FRAGATA
Movant
Purok 1, Mabini, Santiago City

Copy furnished:

Police Regional Office 2

Camp Adduru, Tuguegarao City, Cagayan
-by registered mail w/ return card

2
Annex “B”
3
Annex “C”
4
Annex “D” to “D-3”