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  • Motion To Release Confiscated Items

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    Jil Macasaet
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    The motion requests the release of firearms and ammunition confiscated during a search of the respondent's property. The search was conducted based on a warrant for violation of the Comprehensive Firearms and Ammunition Regulation Act, but the complaint was later dismissed due to insufficient evidence. The motion argues that the respondent's firearms licenses for the M16 and M14 rifles were still valid at the time of confiscation. As the case was dismissed, the respondent requests the return of the confiscated items.

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    Motion to Release Confiscated Items

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    The motion requests the release of firearms and ammunition confiscated during a search of the respondent's property. The search was conducted based on a warrant for violation of the Comprehensive Firearms and Ammunition Regulation Act, but the complaint was later dismissed due to insufficient evidence. The motion argues that the respondent's firearms licenses for the M16 and M14 rifles were still valid at the time of confiscation. As the case was dismissed, the respondent requests the return of the confiscated items.

    Copyright:

    © All Rights Reserved
    Als DOCX, PDF, TXT herunterladen oder online auf Scribd lesen
    Markieren Sie unangemessene Inhalte
    1K Ansichten3 Seiten

    Motion To Release Confiscated Items

    Hochgeladen von

    Jil Macasaet
    The motion requests the release of firearms and ammunition confiscated during a search of the respondent's property. The search was conducted based on a warrant for violation of the Comprehensive Firearms and Ammunition Regulation Act, but the complaint was later dismissed due to insufficient evidence. The motion argues that the respondent's firearms licenses for the M16 and M14 rifles were still valid at the time of confiscation. As the case was dismissed, the respondent requests the return of the confiscated items.

    Copyright:

    © All Rights Reserved
    Als DOCX, PDF, TXT herunterladen oder online auf Scribd lesen
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    von 3

    DEPARTMENT OF JUSTICE

    REPUBLIC OF THE PHILIPPINES


    NATIONAL PROSECUTION SERVICE
    LIPA CITY

    PO2 ROMULO S. DDDDD, JR.


    Complainant,

    -versus- For:

    DDDDDDFF FFFFF y FFFFF, VIOLATION OF R.A 10591


    Respondent, (Comprehensive Firearms
    and Ammunition
    Regulation Act)

    x-----------------------------------------------------------------------------------------x

    MOTION TO RELEASE CONFISCATED ITEMS

    Respondent by himself and unto to this Honorable Office, most


    respectfully avers that:

    1. On March 6, 2019, operatives of PNP Lipa City


    implemented Search Warrant #19-2229 issued by Judge Cynthia R.
    Marino-Ricablanca dated March 4, 2019 for violation of R.A. No.
    10591.

    2. The implementation of such search warrant led to the


    confiscation of the following items:

    a. One (1) M16 rifle with SN 306811 marked RSP1 loaded


    with one (1) magazine marked RSP2 containing twenty (20) live
    ammunitions for said M16 rifle placed inside a plastic marked
    RSP2-1;

    b. One (1) black pouch marked RSP3 containing Twenty-six


    (26) live ammunitions for caliber 5.56 taped together and
    marked RSP3-1, and one (1) box containing thirty (30) caliber
    5.56 ammunitions marked RSP4;

    c. One (1) Colt MK IV Caliber 45 with SN FA24224 marked


    RSP5 loaded with one (1) magazine marked RSP6 containing
    Six (6) live ammunitions for Caliber 45 taped together and
    marked RSP6-1;

    d. One (1) black firearm holster marked RSP7;


    e. One (1) bullet box containing Fifteen (15) live
    ammunitions for Caliber 45 marked RSP8;

    f. One (1) green bullet box marked RSP9;

    g. One (1) black rifle bag marked DTMA containing one (1)
    M14 rifle with SN 1371845 marked DTM; one (1) magazine for
    said M14 rifle marked with DTM1 containing seventeen (17) live
    ammunitions for Caliber 7.62 put inside a plastic and marked
    DTM12; and

    h. One (1) black toolbox marked RSP containing Seven (7)


    long magazine for M16 rifle marked RSP-A, four (4) short
    magazines for M16 rifle marked RSP-B, one (1) red bag
    containing one hundred forty-one (141) live ammunitions for
    Caliber 7.62 marked RSP-C and One (1) dirty cloth bag
    containing seventy-nine (79) live ammunitions for Caliber 5.56.

    3. However, upon verification with the Firearms and


    Explosive Office, the foregoing listed items, particularly the M16 and
    M14 rifles, were licensed to Respondent with expiration on 11
    February 2020. Meanwhile, there is no evidence to show that
    Respondent possessed the Colt MK IV Caliber, which is a firearm
    registered under the name of Respondent’s wife.

    4. Thus, as per Resolution dated 03 May 2019, penned by


    Assoc. City Prosecutor Rea L. Morcilla-Olap, and approved by
    Deputy City Prosecutor Danilo M. Kasilag and City Prosecutor
    Nonilon L. Tagalicud, the complaint for Violation of Republic Act No.
    10591 against Respondent was dismissed for insufficiency of
    evidence.

    PRAYER

    WHEREFORE, it is most respectfully prayed that this


    Honorable Office release the abovementioned confiscated items
    subject of this case.

    Other reliefs that are just and equitable are likewise prayed for.

    Respectfully submitted.

    July 10, 2019, Lipa City, Philippines.

    DDDDDDFF FFFFF y FFFFF

    Page 2 of 3
    Respondent/Movant

    Copy Furnished:

    PO2 ROMULO S. DDDDD, JR.


    PO2 DENNIS T. EEEEE

    Branch __ Regional Trial Court, Lipa City

    Page 3 of 3

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