REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT
Branch 43, Quezon City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- CRIM. CASE NO. M-QZN-19-07902-

CR
FOR: ROBERRY OF A PRIVATE
BUILDING UNDER ARTICLE 302 OF
THE REVISED PENAL CODE

EVANDER DYCHANGO JR. y

SONJACO and LENNON
BALANA y DAACO,
Accused.
x--------------------------------------x

MOTION TO RELEASE MOTORCYCLE

Accused, through the undersigned Public Attorney unto this

Honorable Court respectfully states that:

1. On 28th June 2019, the Honorable Court issued an Order

permanently dismissing the case against all the accused.

2. One of the evidence seized and was supposed to be presented

before this Honorable Court are the following:

a. One (1) Motorcycle Suzuki Series UK125 color Red

without sidecar bearing Plate No. 5287RQ with Engine
No. F4C9204269 and Chasis No. CF48X104269 model 2010
owned by Ricardo Quiambao.

3. There being evidence on record that the subject Motorcycle and

finding the accused innocent of the offenses they were charged of and
the case having been dismissed, it is most respectfully moved that the
Motorcycle subject matter of the case, be released in favor of the
Ricardo Quiambao, being its lawful owner.

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Court that the Motorcycle subject matter of
this case be released in favor of Ricardo Quiambao.

Quezon City, 2 August 2019.

Department of Justice
PUBLIC ATTORNEY’S OFFICE
Quezon City District Office
6/F Justice Cecilia Muñoz Palma Hall, DOJ Building
Quezon City Hall Compound
Diliman, Quezon City

By:

BENJAMIN JEPTHA L. TAN

Public Attorney I
Roll of Attorney No. 71397
IBP No. 057997; December 27, 2018
MCLE Compliance No. VI-0022014; 15 April 2019

Copy furnished:
ACP VIRGILIO R. FOLLOSCO
DOJ BUIDLING, Office of the City
Prosecutor Quezon City