REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE-REGION III
OFFICE OF THE CITY PROSECUTOR
CITY OF SAN JOSE DEL MONTE, BULACAN

PEOPLE OF THE PHILIPPINES CRIM. CASE NO. : 2018-SJ-0030

Plaintiff, NPS DOCKET NO : III-15-INQ-18A-
00020
-versus- -for-

ARNULFO MORENO JR. RECKLESS IMPRUDENCE RESULTING

y ORPILLA IN HOMICIDE
Accused.
x—————————————-x

MOTION TO RELEASE

Comes Now, the movant ARNULFO O. MORENO JR., unto this Honorable
Office, most respectfully state that:

Movant is the absolute and lawful owner and in possession of Volvo S40 car
with Plate No. WDW 882 and Professional Driver’s Licence No. N25-11-010190;

That the above vehicle and driver’s licence card are currently impounded at
the Police Station of the City of San Jose Del Monte, Bulacan, by virtue of the filing
of the aforesaid case;

On January 11, 2018, around 9:00 o’clock in the morning, the movant was
involved in a vehicular accident, while driving the above vehicle, at Cedar St., Grand
Cypress, Brgy. Tungkong Mangga, City of San Jose Del Monte, Bulacan, wherein he
accidentally bumped, Prince Rovin S. Sapra, 3 years old, who suddenly crossed the
street despite the presence of his mother. The movant, with the boy’s mother,
brought the young child to Brigino Hospital but the latter succumbed to death while
undergoing treatment;

It is respectfully prayed that the above personal property, i.e. vehicle and
driver’s license card, be released to the movant so he can safe keep and use the
same;

The movant promises that should the Honorable Office of the City Prosecutor
or the Court find it necessary to produce the same during the course of the
proceedings and or trial, movant undertakes to produce the same.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court that the aforementioned vehicle and driver’s license card be
released to the undersigned movant in the interest of substantial and fair justice.

Other relief just and equitable under the premises are likewise prayed for.

City of San Jose Del Monte, Bulacan, January 31, 2018.

ARNULFO O. MORENO JR.

Accused/Movant
Republic of the Philippines)
Province of Bulacan)
City of San Jose Del Monte) S.S.

AFFIDAVIT OF UNDERTAKING

I, ARNULFO O. MORENO JR., of legal age, Filipino, married, a resident of

Block 12, Lot 35, Cedar St., Grand Cypress, Brgy. Tungkong Mangga, City of San
Jose Del Monte, Bulacan, after having been duly sworn to in accordance with law,
hereby depose and state:

1. I am the Accused/Movant in a Motion to Release personal property, i.e.

Volvo S40 car with Plate No. WDW 882 and Professional Driver’s Licence No.
N25-11-010190, relative to Criminal Case No. 2018-SJ-0030 and NPS Docket No.
III-15-INQ-18A-00020, for Reckless Imprudence Resulting in Homicide, which are
currently impounded at the Police Station of the City of San Jose Del Monte,
Bulacan, by virtue of the filing of the aforesaid case;

2. In support of said Motion to Release personal property, I am executing the

foregoing Affidavit of Undertaking, in strict and faithful compliance with the
requirements of law, and thus hereby undertake to produce said personal property
should the Honorable Office of the City Prosecutor or the Court find it necessary to
produce the same during the course of the proceedings and or trial of the above
mentioned case.

3. I am executing the foregoing Affidavit of Undertaking in order to attest to

the truth of the foregoing as well as for all legal intents and purposes it may serve.

City of San Jose Del Monte, Bulacan, January 31, 2018.

END OF AFFIDAVIT.

ARNULFO O. MORENO JR.

Affiant

SUBSCRIBED AND SWORN TO before me this ____ day of January 2018, at San
Jose Del Monte City, Bulacan. Affiant exhibiting to me his GSIS ID No.
006-0036-2164-6 as his means of identification.