CRISTITA BROSAS DIAZ

MOTIION TO RELEASE VEHICLE (PAJAK)

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Republic of the Philippines

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR
Legazpi City

MOTION TO RELEASE
VEHICLE (PAJAK)

Case No: V-08-INQ-18F-00071

For: Theft

CRISTITA BROSAS DIAZ

Applicant,
x-----------------------------------x

MOTION TO RELEASE VEHICLE

COMES NOW, Applicant registered owner, CRISTITA BROSAS
DIAZ and unto the Office of the Provincial Prosecutor, Legazpi
City, respectfully avers that:

1. Applicant, CRISTITA BROSAS DIAZ, is of legal age,

Filipino, single, and a resident of Cale, Tiwi, Albay;

2. She is the registered owner of a Pajak issued with

Plate No. 2029 which was driven by Edwin De los Santos
Cruzada. Copy of the Original Receipt issued by the
Municipality Of tiwi and the contract with her driver are
herewith attached as annexes “A and B”, respectively;

3. Edwin De los Santos, was a suspect to an alleged

crime of theft last June 9, 2018, that was entered in Police
Blotter of PNP Tiwi, Albay, and docketed as V-08-INQ-18F-0071
in the records of this Honorable Office;

4. As a consequence, the said vehicle was impounded by

the police officer;

5. Herein Applicant, as the owner of the said vehicle,

is not in any way involved in any crime or illegal activity
of his driver, if there was any, or whatsoever, in violation
of law or ordinance;

6. The said Pajak is being rented or used every day

under a boundary system arrangement in order to augment or
earn an additional or extra Income for the family;

7. As result thereof, herein petitioner is suffering

and further incurring losses in the meantime that the case
against her driver is still pending; and

8. She has already executed the corresponding

affidavit of undertaking to cooperate if necessary for the
immediate resolution or settlement of the abovementioned
CRISTITA BROSAS DIAZ
PETITION FOR RELEASE OF MOTOR VEHICLE
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case. Copy of the undertaking is herewith attached as Annex

“C”.

PRAYER

WHEREFORE, it is respectfully prayed unto the Honorable

Office that this petition be considered and that the said
vehicle (Pajak) be released.

Legazpi City, Philippines, 29 June, 2018.

CRISTITA BROSAS DIAZ

Applicant

VERIFICATION
I, CRISTITA BROSAS DIAZ, of legal age, Filipino, single,
and a resident of Cale, Tiwi, Albay, Philippines after having
been duly sworn by law, hereby depose and say, that:

1. I have caused the preparation of the foregoing motion;

2. I have read the contents of said motion and that all

the allegations contained thereon are true and correct
to the best of my knowledge and belief;

3. I have not commenced any other action or proceeding

involving the same issues in the Supreme Court (SC),
the Court of Appeals (CA), or any other tribunal or
agency;and

4. If I should thereafter learn that a similar action or

proceeding has been filed or is pending before the
tribunal or agency , I undertake to report this fact
within five (5) days therefrom to the court or agency
wherein the original pleading and this certification
have been filed.

IN WITNESS WHEREOF, i have affixed my signature this 29th

June 2018 at Legazpi City, Philippines.

CRISTITA BROSAS DIAZ

Applicant
CRISTITA BROSAS DIAZ
PETITION FOR RELEASE OF MOTOR VEHICLE
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SUBSCRIBED AND SWORN TO before me this 29TH day of June

2018 at Legazpi City,Albay, Philippines by the above-named
affiant who executed the foregoing Verification. Affiants
further exhibited to me her Voters Identification card with
VIN No. 0518-0042A-F2 as competent proof of identity pursuant
to Rule 2, Sec. 12(a) of the 2004 Rules on Notarial Practice.

Doc. No. ___

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