Republic of the Philippines

Department of Justice
National Prosecution Service
OFFICE OF THE PROSECUTOR
Ilagan City, Isabela
x----------------------------------------------------------------------------x
Republic of the Philippines
Second Judicial Region
REGIONAL TRIAL COURT
Branch 18
Ilagan City, Isabela

THE PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- Blotter Entry No. 495

JERICHO CHAVEZ
Accused.
x----------------------------------------------x

MOTION TO RELEASE MOTOR VEHICLE

I am respectfully requesting the release to my custody the motor

vehicle which was impounded by virtue of the filing of the above-
mentioned case and in connection therewith, I declare under oath:

1. That I am the Branch Manager of Kevin Henry Marketing

Corporation Ilagan City, Isabela from which the Honda MC
Model registered under the name of Bryan E. Galvizo was
purchased. Copy of the record of payment is hereto attached
and made integral part hereof as Annex “A”.

2. That the said vehicle is more particularly described as follows,

to wit:
Make: Honda
Type: Motorcycle
Model: TMX125
Color: Black
Plate Number: BP23872
Series: CCG125WHF
 Chassis Number: KSW00188179
Engine Number: KSW00E188112

As evidenced by the certified true copies of its Certificate of

Registration with Official Receipt which are hereto attached and
made integral part hereof as Annex “B”;

3. That the aforementioned motor vehicle was involved in the

above-mentioned case last December 08, 2016 in District III,
Gamu, Isabela;

4. That at present, the above-mentioned vehicle is impounded at

and under the custody and control of the Philippine National
Police, Gamu, Isabela by virtue of the filing of the above case.

5. That I move for the release of the same as it is being exposed

to the elements and in so doing, might cause rust damage to
the motorcycle.

6. That truth to tell, the said motor vehicle is yet to be paid in full
by the accused and it would be for the advantage of the
company, the accused and the court if the same be released in
our custody.

Attached hereto and made integral part hereof as Annex “C” is

the Affidavit of Undertaking executed in support of this motion.

7. That I am willing to substitute the same with certified true

copies of its Certificate of Registration and Official Receipt.

8. That this motion is filed in the interest of justice.

 WHEREFORE, premises considered, it is most respectfully prayed
of this Honorable Office that an Order be issued directing the Gamu
Municipal Police Station, Gamu, Isabela, to release the aforesaid vehicle
to the movant at the soonest possible time.

Cauayan City, Isabela. December 04, 2019

RANDY M. ACOBA
Movant

SUBSCRIBED AND SWORN to before me this ___ day of December,

2019 at Cauayan City, Isabela, Movant exhibiting to me his competent
proof of identity,

Doc No.
Page No. Notary Public
Book No.
Series of 2019

Copy furnished:

PHILIPPINE NATIONAL POLICE

Gamu, Isabela
REPUBLIC OF THE PHILIPPINES )
PROVINCE OF ISABELA ) S.S.

AFFIDAVIT OF UNDERTAKING

I, Randy M. Acoba, of legal age, Filipino with office address at

District 1, Don Jose Canciller Ave., Cauayan City, Isabela, after having
been sworn in accordance with the law hereby depose and state that:

1. I am the Assistant Area Manager of Kevin Henry Marketing

Corporation Ilagan City from which the Honda MC Model
registered under the name of Bryan E. Galvizo was purchased;

2. Sometimes last December 08, 2016, Jericho Chavez, the

borrower of the motorcycle, was involved in an incident as per
Blotter Entry Number 492 of the Philippine National Police, Gamu
Municipal Police Station. Copy of the Certification is hereto
attached as Annex “A”;

3. Because of such incident and by virtue of the information filed

against Jericho Chavez before the RTC Ilagan City, the vehicle
that he was driving was impounded by the Gamu Municipal Police
Station, Gamu, Isabela;

4. I hereby undertake to produce said vehicle upon request of the

Honorable Office of the Prosecutor and/or the Honorable Court
where the case against the accused has been filed if such will be
needed for further proceedings or investigation.

5. This affidavit is being executed to support my request for the

release of the impounded vehicle;

6. I am executing this undertaking to attest to the truth of the

foregoing.
 IN WITNESS WHEREFORE, I have hereunto set my hands this
______ day of December 2019 in Cauayan City, Isabela, Philippines.

RANDY M. ACOBA
Movant

SUBSCRIBED AND SWORN TO before me this _____ day of

December, 2019 in the City of Cauayan, Isabela, Philippines, Movant
exhibiting to me his competent proof of identity.

Doc No.
Page No. Notary Public
Book No.
Series of 2019