Republic of the Philippines

DEPARTMENT OF JUSTICE
OFFICE OF THE PROVINCIAL PROSECUTOR
Hall of Justice Compound, Aguinaldo Highway
Imus City, Cavite

PNP-PHPT CAVITE,
Complainant,

- versus - DOCKET NO. IV-03-INV-18H-2898

MARIO GUTIERREZ
Respondent.
x--------------------------------------------------x

MOTION FOR THE RELEASE

OF MOTOR VEHICLE

UNDERSIGNED MOVANT, unto this Honorable Office most

respectfully avers and states that:

1. The instant case against the above-named respondent, MARIO

GUTIERREZ, involves a TOYOTA HI-ACE (vehicle) with CONDUCTION
STICKER number: YY5161, which has been confiscated/impounded by the
police officers of PHPT – CAVITE when the respondent was arrested.

2. The owner of the said motor vehicle is JUAN VILLAMOR as

reflected in the LTO Certificate of Registration/having purchased the vehicle
from TOYOTA ALABANG dealership.

3. The subject vehicle was purchased by the owner for the

purposes of family use and assistance in the family business.

4. The owner is in urgent need of the subject vehicle, which is still

registered under the name of JUAN VILLAMOR.

5. The subject vehicle by its nature needs proper maintenance

which can only be done by the owner if the said vehicle is in his custody.

6. To have the subject vehicle continuously impounded in the

police premises/HPG without proper maintenance would surely cause
damage to the engine systems of the vehicle and would certainly expose it
to some physical and environmental hazards.

7. Herein movant hereby expressly commits and undertakes to

surrender and bring to this Honorable Office and or to any Court of Justice
the subject vehicle if the need arises and upon proper notice.

1
 PRAYER

WHEREFORE, premises considered, it is most respectfully prayed

that the impounded vehicle now in custody of the PHPT-CAVITE Police
Department be released upon the person of the herein owner-movant and
considering the hereto attached Affidavit of Undertaking.

Other reliefs and remedies which are just and equitable under the
premises are likewise prayed for.

Trece Martires City for Imus, Cavite, 10 August 2018.

ANNA CARISSA L. CANILAO

NOTICE OF HEARING
GREETINGS:

Please submit and set the foregoing Motion for the approval of this
Honorable Office on 15 August 2018 at 10:00 in the morning.

ANNA CARISSA L. CANILAO

Republic of the Philippines )

_____________________ ) S.S.

VERIFICATION

I, ANNA CARISSA L. CANILAO, of legal age, Filipino and residing at

Tanza-Trece Road, Brgy. San Agustin, Trece Martires City, Cavite, after
having been duly sworn to in accordance with law do hereby states that:

a) I have caused the preparation and filing of the foregoing Motion;

and

b) I have read and understood the same and the contents thereof,
them being true and correct of my personal knowledge and/or are
based on authentic records.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

_____ day of August 2018 at __________________________.

ANNA CARISSA L. CANILAO

Subscribed and Sworn to before me this _____ day of August 2018 at

_________________, Philippines, affiant exhibiting to me her
_________________ (competent evidence of identity).

Doc. No. ___;

Page No. ___;
Book No. ___;
Series of 2018.
Republic of the Philippines )
_____________________ ) S.S.

AFFIDAVIT OF UNDERTAKING

I, ANNA CARISSA L. CANILAO, of legal age, Filipino and residing at

Tanza-Trece Road, Brgy. San Agustin, Trece Martires City, Cavite, after
having been duly sworn to in accordance with law do hereby states that:

1. That I am the representative of the owner of one (1) TOYOTA

(HI-ACE) (vehicle) with conduction sticker: YY5161, which has been
confiscated/impounded by the police officers of PHPT-CAVITE;

2. That the affiant herein undertakes to produce the vehicle

of the above-mentioned owner whenever the Honorable Prosecutors Office
so requires.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

_____ day of August 2018 at __________________________.

ANNA CARISSA L. CANILAO

Subscribed and Sworn to before me this _____ day of August 2018 at

_________________, Philippines, affiant exhibiting to me her
_________________ (competent evidence of identity).

Doc. No. ___;

Page No. ___;
Book No. ___;
Series of 2018.