Republic of the Philippines

6th Judicial Region

BAROTAC NUEVO MUNICIPAL TRIAL COURT
Barotac Nuevo, Iloilo

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. xxx

Plaintiff,
FOR: Reckless Imprudence
-versus- Resulting in Homicide
and Damage to Property
AAA,
Accused.
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MOTION TO RELEASE IMPOUNDED VEHICLE

COMES NOW, movant BBB, by herself, unto this Honorable Court

most respectfully states that:

1. Movant, with residential address at CCC, is the registered

owner of an Isuzu Wing Van bearing temporary Plate No. xxx, as
evidenced by Certificate of Registration and Official Receipt issued by the
Land Transportation Office, copies of which are hereto attached as
Annexes "A" and "A-1";

2. Said vehicle was involved in a vehicular accident on

November 4, 2019 at around 9:25 in the evening in Barangay Acuit,
Barotac Nuevo, Iloilo, causing the death of one DDD;

3. Said vehicle was impounded and currently under the custody

of the Barotac Nuevo Municipal Police Station;

4. Said vehicle is being utilized by the Movant in her business,

and is never intended to be used for any illegal purpose;

5. Since a Compromise Agreement has been executed by the

Accused and the private complainant, Movant now prays for the release
of the said vehicle;
Motion to Release Impounded Vehicle
Page 2 of 3

6. This motion is not intended to delay the proceedings of this

case but solely for the reasons stated above.

WHEREFORE, premises considered, it is most respectfully prayed

that an Order be issued for the release of the above-described vehicle
from the custody of the Barotac Nuevo Municipal Police Station and
deliver the same to Movant.

Other reliefs just and equitable are likewise prayed for.

Respectfully submitted, Barotac Nuevo, Iloilo, ____________________.

BBB
Movant
Motion to Release Impounded Vehicle
Page 3 of 3

NOTICE OF HEARING

Branch Clerk of Court

Barotac Nuevo Municipal Trial Court
Barotac Nuevo, Iloilo

Please submit the foregoing Motion for the consideration and

resolution of the Honorable Court immediately upon receipt hereof.

BBB

______________________________
Office of the Provincial Prosecutor
Ramon Q. Avanceña Hall of Justice
Bonifacio Drive, Iloilo City

Please take notice that the foregoing motion shall be submitted for
the kind consideration and resolution by the Honorable Court
immediately upon receipt hereof.

BBB

Copy furnished by personal service:

______________________________
Office of the Provincial Prosecutor
Received by: ______________________________
Date: _______________

The Chief of Police

Barotac Nuevo Municipal Police Station
Barotac Nuevo, Iloilo
Received by: ______________________________
Date: _______________