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Republic of the Philippines

Fourth Judicial Region
REGIONAL TRIAL COURT
Branch 3
Bulwagan ng Katarungan
Pallocan West, Batangas City

THE PEOPLE OF THE

PHILIPPINES, Criminal Case No. 20297
Plaintiff,
for

-versus- Violation of Section 5, Article II

Of Republic Act 9165, Otherwise
Known as the Comprehensive
Dangerous Drugs Act of 2002
WARREN VILLENA y RAMOS,
@”ALLEN”
Accused.
x--------------------------------------------x

MOTION TO RELEASE VEHICLE

COMES NOW, the accused in the above entitled case by and

through his undersigned counsel and to this Honorable Court most
respectfully states:

1. That the accused was charged of the crime of Violation of

Section 5, Article II of Republic Act No. 9165 otherwise known as
the Comprehensive Dangerous Drugs Act of 2002;

2. That according to the arresting officer, on or about September

23, 2015 at around 8:20 in the evening at Brgy. Cuta, Batangas City
accused not being authorized by law criminally transport or deliver,
with the use of a motor vehicle (Kawasaki Barako), a motorized
tricycle without plate number (for registration), Ten (10) heat sealed
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transparent plastic sachets containing shabu with an aggregate

weight of 38.72 grams;

3. That after the prosecution has rested its case, accused through
counsel filed his Demurrer to Evidence which the court granted the
same as shown by the Order dated November 17, 2017;

4. That in the said Order, accused was acquitted and the subject
specimens in this case with an aggregate weight of 38.72 grams of
shabu were ordered confiscated and to be disposed of pursuant to
law;

5. That nothing in the said Order regarding the confiscation of the

Kawasaki Barako, a motorized tricycle without plate Number;

6. That due to such, accused being the absolute and registered

owner of the motorcycle as shown by the Certificate of Registration
Bearing No. 232424780 dated January 20, 2016 and Official Receipt
No. 826586202 dated January 20, 2016, certified photocopies of
which are hereto attached for ready reference, is praying that the said
Kawasaki Barako, a motorized tricycle without plate Number be
returned to him.

WHEREFORE, premise considered it is most respectfully prayed of

this Honorable Court that an Order be issued directing the evidence
custodian of the Batangas City Police Station to release the aforesaid
vehicle in favor of accused Warren Ramos Villena.

Other reliefs and remedies available in the premises are likewise

prayed for.

Batangas City, April 19, 2018.

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JOSELITO M. DIMAYACYAC
Counsel for the Accused
Rm. 3, Golden Luck Building,
Apacible Street, Batangas City
Roll No. 26881
PTR No. 3021636/Batangas City/ 01-3-2018
IBP No. 1065657/Batangas City/1-3-2018
MCLE Compliance No. V-0015329/Valid Until:4-14-19

NOTICE

Office of the City Prosecutor

Hall of Justice
Batangas City

The Branch Clerk of Court

RTC Branch 3,
Batangas City

G R E E T I N G S:

Upon receipt hereof, please submit the foregoing Motion to Release

Vehicle to the Honorable Court for its consideration and approval on April
23, 2018 at 8:30 o’clock in the morning.

Batangas City, April 19, 2018.

JOSELITO M. DIMAYACYAC

Copy Furnished:

Office of the City Prosecutor

Hall of Justice, Batangas City

warren villena 1-20-18