Scribd Logo
Upload

Welcome to Scribd!

  • 1K views

    Motion To Release Vehicle

    Uploaded by

    Xhain Psypudin
    1) The motion requests the release of a mortgaged motorcycle from police custody that was impounded as evidence in a criminal case. 2) The motorcycle was purchased on a mortgage loan but the accused has failed to make payments since 2019. 3) As the branch manager of the motorcycle company, the movant exercised the right to repossess the vehicle and now requests its release with the undertaking that it will be produced whenever required.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Motion To Release Vehicle

    Uploaded by

    Xhain Psypudin
    1K views3 pages
    1) The motion requests the release of a mortgaged motorcycle from police custody that was impounded as evidence in a criminal case. 2) The motorcycle was purchased on a mortgage loan but the accused has failed to make payments since 2019. 3) As the branch manager of the motorcycle company, the movant exercised the right to repossess the vehicle and now requests its release with the undertaking that it will be produced whenever required.

    Original Description:

    SAMPLE MOTION TO RELEASE VEHICLE

    Original Title

    motion to release vehicle

    Copyright

    © © All Rights Reserved

    Available Formats

    DOCX, PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    1) The motion requests the release of a mortgaged motorcycle from police custody that was impounded as evidence in a criminal case. 2) The motorcycle was purchased on a mortgage loan but the accused has failed to make payments since 2019. 3) As the branch manager of the motorcycle company, the movant exercised the right to repossess the vehicle and now requests its release with the undertaking that it will be produced whenever required.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    1K views3 pages

    Motion To Release Vehicle

    Uploaded by

    Xhain Psypudin
    1) The motion requests the release of a mortgaged motorcycle from police custody that was impounded as evidence in a criminal case. 2) The motorcycle was purchased on a mortgage loan but the accused has failed to make payments since 2019. 3) As the branch manager of the motorcycle company, the movant exercised the right to repossess the vehicle and now requests its release with the undertaking that it will be produced whenever required.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 3

    Republic of the Philippines

    Department of Justice
    National Prosecution Service
    PROVINCIAL PROSECUTION OFFICE OF ZAMBOANGA DEL SUR
    Pagadian City
    -o0o-

    People of the Philippines, I.S. No. 123456


    Plaintiff, Criminal Case No. 123123

    -vs- -for-

    ABCD . Reckless Imprudence Resulting


    Accused. Slight Physical Injuries
    x------------------------------/

    MOTION TO RELEASE MOTOR VEHICLE

    Movant, assisted by counsel, unto the Honorable Office of the Provincial


    Prosecutor of Zamboanga del Sur most respectfully state and aver: THAT:

    1. He is the branch manager of MOTORS Balangasan, Pagadian City


    Branch, with business address at, Balangasan District, Pagadian City;

    2. That PEDRO,( herein accused) purchased a motor on January 8, 2018


    vehicle from MOTORS Pagadian Branch by way of SALE WITH
    CHATTEL MORTGAGE and is particularly described as follows:

    MAKE: HONDA SERIES: 123132


    ENGINE NO: 2525252 BODY TYPE: MOTORCYCLE
    CHASSIS NO.: 25252252 YEAR MODEL: 2017

    (Hereto attached as Annex “A” is the Sale with Chattel Mortgage)

    3. PEDRO likewise executed a Deed of Reconveyance in favor of


    MOTORS Pagadian Branch, in the event that he fails to pay his
    monthly obligations to MOTORS of his mortgaged above-described
    motor vehicle;(hereto attached and marked as Annex “B” in the Deed
    of Reconveyance)

    4. On April 1, 2019, above-described motor vehicle was involved in a


    vehicular accident on V. Sagun, Zamboanga del Sur and presently
    impounded at the Municipal Police Station of V. Sagun, Zamboanga
    del Sur;

    5. PEDRO was charged before the Branch 15, MCTC


    MARGOSATUBIG-VICENZO SAGUN, ZAMBOANGA DEL SUR
    under Criminal Case No. 123123 and the above-described motor vehicle
    is under custody of the Municipal Police Station of V. Sagun,
    Zamboanga del Sur as it is being utilized as evidence for the
    Prosecution;

    6. Since April 2019, PEDRO failed to pay his monthly obligations with
    MOTORS Pagadian Branch in connection to the mortgaged motor
    vehicle as evidence by the certification issued by the Branch Cashier,
    Darlyn C. Bangcaya;
    (hereto attached and marked as Annex “C” is the said certification)

    7. Thus, as the branch manager of MOTORS Pagadian Branch, movant


    exercised the right of MOTORS Pagadian Branch to reconvey the
    above-described motor vehicle.

    8. Movant, on behalf of MOTORS Pagadian Branch, hereby undertake to


    produce the above-described motor vehicle before the court and the
    Office of Provincial Prosecutor whenever required by the same. (hereto
    attached and marked as Annex “D” is the Affidavit of Undertaking of
    JOsE.

    PRAYER

    Premises considered, it is most respectfully prayed to the Honorable


    Prosecutor to release the custody of above-described motorcycle from the
    Municipal Police Station of V. Sagun, Zamboanga del Sur unto the MOTORS
    Pagadian Branch, with an undertaking that the same will be produced by the
    movant whenever required by the Office of the Provincial Prosecutor or the
    Honorable Court.

    Other just and equitable relief is likewise prayed for.

    Respectfully submitted this _____________________, in Pagadian


    City, Philippines.

    PO
    Counsel for Petitioner
    Roll Of Attorney No. 2132123
    PTR No. 6656465
    IBP No. 654654654
    MCLE VI Compliance No. 564654654
    Pagadian City
    VERIFICATION AND CERTIFICATION

    Republic of the Philippines)


    CITY OF PAGADIAN…...) S.S.
    x-----------------------x

    I, jose, of legal age, Filipino, married, and resident of, Kagawasan,


    Pagadian City, Philippines, after being sworn in accordance with law, hereby
    depose and say:

    That I am the OPERATOR of MOTORS Balangasan, Pagadian City


    Branch, in the above-entitled case; That I have caused the preparation of the
    above Motion and I have read the same and knows the contents thereof; That
    the allegations contained therein are true and correct of my own personal
    knowledge.

    That I further certify that: (a) I have not theretofore commenced any
    other action or proceeding or filed any claim involving the same issues or
    matter in any court, tribunal, or quasi-judicial agency and, to the best of my
    knowledge, no such action or proceeding is pending therein; (b) if I should
    thereafter learn that the same or similar action or proceeding has been filed or
    is pending before the Supreme Court, the Court of Appeals, or any other
    tribunal or quasi-judicial agency, I undertake to report such fact within five
    (5) days therefrom to the court or agency wherein the original pleading and
    sworn certification contemplated herein have been filed.

    IN WITNESS WHEREOF, I have hereunto set my hand this -


    ____________________ at Pagadian City, Philippines.

    jose
    AFFIANT

    SUBSCRIBED AND SWORN to before me, this


    ___________________ whom I have identified through competent evidence
    of identity who exhibited to me his 13213213213213

    Doc. No. ______;


    Page No. ______;
    Book No. ______;
    Series of 2020;

    You might also like