Republic of the Philippines

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE, REGION III
OFFICE OF THE PROVINCIAL PROSECUTOR
Malolos City, Bulacan (3000)

PEOPLE OF THE PHILIPPINES,

-versusJANUARY NAZAR y MANIQUIZ,
Of Barangay Ilog-Bulo, San Miguel,
Bulacan,
Accused.
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Crim Case No. CRIM. CASE NO. ______

For: RECKLESS IMPRUDENCE
RESULTING IN HOMICIDE

MOTION TO RELEASE MOTOR VEHICLE

COMES NOW, HELEN A. PALOMO, by herself, unto the Honorable Provincial
Prosecutors Office most respectfully state:
1. That, the movant with residential address at Barangay Ilog-Bulo, San Miguel,
Bulacan, is the registered owner of an Isuzu Dump Truck with plate RFP272,
copy of the Official Receipt/Certificate of Registration (OR/CR) attached hereto
as Annex 1;
2. That, the said motor vehicle was involved in a vehicular accident on December
23, 2015 at about 4:40 in the afternoon in Barangay Makapilapil, San Ildefonso,
Bulacan causing the death of ANDREI NUEZ TINAWIN;
3. That, the said motor vehicle was impounded and currently under the custody of
the San Ildefonso Police Station;
4. That, the movant herein requested for the immediate release of the impounded
vehicle in view of the fact that the said vehicle in conducting legitimate business
to earn a living that it was never intended to be used for any illegal purpose;
5. That, the continued impounding of said motor vehicle has directly or indirectly
deprived the herein movant of its work-related and personal use and has
impaired her capacity to earn. In addition, continued impounding of said vehicle
would further caused its deterioration;
6. That, the herein movant undertakes to present the said motor vehicle to the court
whenever needed, upon due notice, attached herewith is the Undertaking duly
executed by the herein movant as Annex 2;
7. That, the herein movant was not able to present the original copy of the OR/CR
as it was in the custody FINASWIDE CREDIT CORP. as collateral for a truck loan
that the former has with the latter, as evidenced by a CERTIFICATION dated
January 13, 2016, attached herewith as Annex 3;
8. That, as proof of the absolute ownership of the herein movant of the said motor
vehicle, a CERTIFICATION dated January 13, 2016 (Annex 4) and the
corresponding Official Receipt (Annex 4-1) issued by the Land Transportation
Office, to the effect that as per available records in the said office, the registered
owner is the herein movant;
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9. That, attached as Annex 5 are the pictures of the said motor vehicle for
reference and for whatever legal purpose it may serve;

PRAYER
WHEREFORE, premises considered, it is respectfully prayed of the Honorable
Provincial Prosecutor that the impounded motor vehicle (Isuzu Dump Truck with plate
RFP272) owned by the afore-mentioned movant be released.
Other reliefs, which are just and equitable, are also prayed for.
Bulacan, January 14, 2016.

HELEN A. PALOMO
Movant

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