Republic of the Philippines

Province of Cagayan
Second Judicial Region
BRANCH 33
Ballesteros, Cagayan

PEOPLE OF THE PHILIPPINES,

-versus- CRIMINAL CASE NO.

33-3072-2021

For: “Violation of Sec. %, Art

II of RA 9165”
ROCHELLE DELOS SANTOS,

Accused.
x----------------------------------------x
                            
MOTION FOR RELEASE OF IMPOUNDED VEHICLE

COMES NOW, movant JONATHAN FLORES, through the

undersigned counsel, and unto this Honorable Court, most respectfully
avers as follows:

1. The movant JONATHAN FLORES is a resident of Annafunan

East, Tuguegarao City and is the registered owner of a Yamaha
Motorcycle with Plate Number 922BGE, more particularly
described as follows:

Make : Yamaha
Type of Bode : Motorcycle
Series : Mio Sporty
Year Model : 2018
Chassis/Frame No.: PA0SEF210J0094276
Engine No. : E31TE-0094551
MV FILE NO. : 0201-00000784107

2. A Motion for Release of Impounded Vehicle has earlier been

submitted by the Movant. An order of this Honorable Court dated
20 June 2022 has been issued denying the said motion
considering that the movant is not yet the registered owner
thereof;

3. With all due respect to the Order of the Honorable Court, the
Movant purchased the said vehicle through a financing system
from Sumisho Motor Finance Corporation;
 4. The Movant paid in full the said vehicle as evidenced by a Deed
of Absolute Sale executed last 10 October 2022, and notarized
last 11 October 2022, with Doc No. 13, Page No. 04, Book No.
01, Series of 2022. A copy of the said Deed of Sale is hereto
attached as Annex “A” for the perusal of this Honorable Court;

5. A certification from Sumisho Motor Finance Corporation is

likewise attached as Annex “B” certifying further that herein
Movant is the rightful owner of the vehicle;

6. The said motorcycle was involved in an incident in the foregoing

case on 04 March 2021 where the accused was allegedly caught
selling illegal drugs;

7. Said vehicle was impounded and is currently under the custody of

Lasam Police Station, Lasam Cagayan;

8. The accused is the wife of my brother-in-law, and out of pity

during that particular day, herein Movant allowed the accused to
use the vehicle without any knowledge as to how it will be used;

9. The continuous impounding of the vehicle brought great damage

and distress to herein Movant as the said transportation vehicle is
being used by him for his daily transport to his employment
including that of his family members;

10. The movant ensures the delivery of the said vehicle or to pay
necessary fees should this Honorable Court deem it necessary
for the complete disposition of the foregoing case;

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of

this Honorable Court that an Order be issued for the release of the
above-described motor vehicle from the custody of the Lasam Cagayan
Police Station and deliver the same to the Movant.

          Other reliefs and remedies as may be deemed just and equitable
under the premises are likewise prayed for.

          Tuguegarao City. 11 October 2022.

GLAESAN G. ADRIANO
NATIVIDAD, SALES & ASSOCIATES Law Offices
2nd Floor Marivic Auto Supply Building, Diversion
Road, Tuguegarao City, Cagayan 3500
IBP Roll #: 77326 – May 2022
PTR OR #: 3103139 – Tug. City; 05/11/2022
IBP OR #: 207515 – 05/07/2022
MCLE (Newly admitted to the Bar/05/07/2022)
CP #: (+63) 919-094-7483
glaeadriano@gmail.com
 NOTICE OF HEARING

TO THE BRANCH CLERK OF COURT

Regional Trial Court
Branch 33
Ballesteros, Cagayan
Greetings!
Being a non-litigated motion, please submit the foregoing motion for
consideration and approval of this Honorable Court immediately upon
receipt hereof.
Thank you!

ATTY. GLAESAN G. ADRIANO

Copy Furnished:

PROS. MURASHID SUSUKAN

Office of the Provincial Prosecutor
Ballesteros, Cagayan