Republic of the Philippines

DEPARTMENT OF JUSTICE
Office of the City Prosecutor
Davao City

GLEN BONGHANOY BATINGAL NPS Docket No. XI-02-INQ-19-G-2225

Requesting Party. For: RECKLESS IMPRUDENCE
RESULTING IN HOMICIDE
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REQUEST FOR RELEASE WITH UNDERTAKING

(Of Recovered Articles by Requesting Party)

HON. NESTOR M. LEDESMA

City Prosecutor
Office of the City Prosecutor
City of Davao

I am respectfully requesting the release of a 2007 Isuzu Giga Aluuminum

Wing Van Truck behicle most particularly described as follows, to wit:

Engine No. : GWF1-401045

Chasis No. : CYL51V5Z-7000074
MV File No. : 0301-620740
Plate No. : CAB3351

which was recovered by the police authorities and presently in the custody of
Talomo Police Station (PS3), Davao City and in connection therewith, I declare
under oath THAT:

1. I am the lawful owner thereof, as evidenced by Certificate of

Registration and Official Receipt, copies of which are hereto attached;

2. Said truck was driven by my driver RENE QUIGOD BAGUIO who

was apprehended by the authorities of Talomo Police Station because of the
aforementioned violation;

3. It is my main source of income to sustain my family’s daily needs,

hence, I hereby request for the release of the same;

4. I undertake to produce the same before your Office or the court

when so required;

5. I have caused the said motor vehicle to be photographed; and

6. I affirm the statement given by me and hereby bind myself under

penalty of law to appear and testify thereon in court when so required;

7. I am executing this instrument to attest to the truth of the foregoing

facts, to apprise the authorities of the truth of the foregoing facts and for whatever
legal purpose this may serve.
 IN WITNESS WHEREOF, I have hereto affixed my signature this 14th
August 2019 in the City of Davao, Philippines.

GLEN BONGHANOY BATINGAL

Requesting Party

SUBSCRIBED AND SWORN to before me this 14th August 2019 in the

City of Davao, Philippines.

Recommending Approval:

___________________________________
Investigating Prosecutor

APPROVED:

PROS. NESTOR M. LEDESMA

City Prosecutor