Republic of the Philippines

REGIONAL TRIAL COURT

_______ Judicial Region
____________________

PEOPLE OF THE PHILIPPINES,

Plaintiff,
-versus- Crim. Case No. ___________
For: Violation of Section 11,
Art II, of RA 9165
_________________________,
Accused.

_________________________,
Movant
X---------------------/

MOTION TO RELEASE AND TAKE CUSTODY OF

SEIZED MOTORCYCLE
COMES NOW, the Movant, by the undersigned counsel, and unto this Honorable
Court most respectfully avers that:

1. Herein movant is the registered owner of the motorcycle more particularly

described, as follows:

Brand: _____________
MODEL: ____________
COLOR: _____________
ENGINE No. _____________
CHASSIS: _______________
OR No.: _________________
CR No.: _________________

Attached hereto is Annex “A” the copy of the O.R and C.R of the said motorcycle
to form as an integral part of this motion;

2. The above-described motorcycle was seized from her son _________________

by the police officers of PNP ____________ Police Station in ________________, who
took custody of the same;

3. That on January 14, 2020, the instant case was terminated through a Judgment
when the accused pleaded guilty to a lesser offense;

4. The subject motorcycle is now lying idle and exposed to extreme weather
condition;

5. Thus, movant-owner is begging the Honorable Court to issue an order releasing

the custody of the said motorcycle to her as its registered owner so he can resume his
ownership over it.
 Wherefore, premises considered, it is most respectfully prayed of this Honorable
Court to grant the foregoing motion and accordingly, issue an order directing the Chief of
Police of PNP __________Police Station or his authorized representative to release and
entrust its custody to the movant-owner _________________ as its registered owner.

Other relief just and equitable are likewise prayed for.

RESPECTFULLY SUBMITTED.

January 17, 2020, _______________________

ATTY. _______________

NOTICE OF HEARING

ATTY. __________
Clerk of Court
RTC-Branch _____
_______________

Dear Sir.

Greetings! Please submit to the Honorable Court for its consideration and approval the foregoing
motion. Thank you.

ATTY. __________________

Copy furnished:

Prosecutor’s name and address

_____________________________________
______________________________________