REPUBLIC OF THE PHILIPPINES

Department of Justice
OFFICE OF THE PROVINCIAL PROSECUTOR
(Office Address)

MERVIN V. BELENO,
Complainant,
-versus- Case No. 878
TOP No. 16875814-4
For: COLORUM
JHONI ALPARO GONZALES
owner
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MOTION FOR RELEASE OF VEHICLE

COMES NOW,JHONI ALPARO GONZALES, by himself, unto the Honorable Provincial Prosecutor’s
Office most respectfully states that:

1. The movant with residential address at EDSA COR V ANG AND GEN EVANGELISTA ST. KALOOKAN
CITY, is the owner of a TOYOTA VIOS SEDAN with plate number NBF5131, particularly described as
follows:

MAKE: TOYOTA
ENGINE NO.: 1NRX382665
CHASSIS NO.: PA1B13F3254074429
COLOR: JADE METALLIC
MV FILE NO.: 130100001257134
PLATE NO.: NBF5131

2. Attached herewith are copies of the Official Receipt and the Certificate of Registration as Annex “A”
and “B”, respectively.

3. That, the said motor vehicle, driven by OLIVER PINEDA JAVIER, was involved in a vehicular
accident on APRIL 19, 2023 at about 3:47 in NAIA TERMINAL 3 for the cause of colorum.

4. The said motor vehicle driven by OLIVER PINEDA JAVIER was impounded and currently under the
custody of the (Police Station / Highway Patrol Group / LTO).

5. The movant herein most respectfully requests for the immediate release of the impounded vehicle
and Proffesional Driver’s License with No. N03 - 09- 010452 in view of the fact that the continued
impounding of said vehicle would further cause its deterioration.

6. The 2nd paragraph of Article 45 of the Revised Penal Code exempts the property owned by a third
person not involved in the incident from being confiscated and forfeited in favor of government.

7. The said vehicle is not owned by respondent-driver but by herein movant who is not a party to this
case.

8. And as since the vehicle had already been processed by the police/traffic investigators at the scene of
the incident, its further detention is no longer warranted.

9. Undersigned movant undertakes to present the said motor vehicle, if released, whenever required by
your Honorable Office or by any court of law.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of the Honorable Provincial Prosecutor

that the impounded motor vehicle owned by herein movant be released.

Other reliefs, which are just and equitable, are also prayed for.

________________________, __________________, Philippines.

JHONI ALPARO GONZALES

Owner