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    Release Vehicle Monsayac

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    magiting mabayog
    Ericson Monsayac has filed an ex-parte motion requesting the release of his impounded motorcycle. He was acquitted of criminal charges involving violation of drug laws and robbery. His wife acquired legal ownership of the motorcycle from the original owner through a financing company. The motorcycle is currently impounded and deteriorating, so Monsayac is asking the court to direct the police to release it to him as its lawful co-owner.

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    Release Vehicle Monsayac

    Uploaded by

    magiting mabayog
    234 views2 pages
    Ericson Monsayac has filed an ex-parte motion requesting the release of his impounded motorcycle. He was acquitted of criminal charges involving violation of drug laws and robbery. His wife acquired legal ownership of the motorcycle from the original owner through a financing company. The motorcycle is currently impounded and deteriorating, so Monsayac is asking the court to direct the police to release it to him as its lawful co-owner.

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    motion to release motor vehicle

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    Ericson Monsayac has filed an ex-parte motion requesting the release of his impounded motorcycle. He was acquitted of criminal charges involving violation of drug laws and robbery. His wife acquired legal ownership of the motorcycle from the original owner through a financing company. The motorcycle is currently impounded and deteriorating, so Monsayac is asking the court to direct the police to release it to him as its lawful co-owner.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    234 views2 pages

    Release Vehicle Monsayac

    Uploaded by

    magiting mabayog
    Ericson Monsayac has filed an ex-parte motion requesting the release of his impounded motorcycle. He was acquitted of criminal charges involving violation of drug laws and robbery. His wife acquired legal ownership of the motorcycle from the original owner through a financing company. The motorcycle is currently impounded and deteriorating, so Monsayac is asking the court to direct the police to release it to him as its lawful co-owner.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    Republic of the Philippines

    REGIONAL TRIAL COURT


    Second Judicial Region
    BRANCH 24
    Echague, Isabela

    PEOPLE OF THE PHILIPPINES,


    Plaintiffs,

    -versus- CRIM.CASE No. 24-2687


    For: Violation of Section 11 of
    R.A. No. 9165

    CRIM. CASE No. 24-2688


    For: Robbery

    ERICSON MONSAY AC y MENDOZA,


    Accused.
    x ------------------------------------------------ x

    MANIFESTATION WITH EX-PARTE MOTION


    TO RELEASE MOTOR VEHICLE

    The undersigned MOVANT ERICSON M. MONSAYAC, by himself, to the


    Honorable Court, most respectfully states THAT:

    1. The movant was charged of Two Criminal Information namely, Violation


    of Section 11 of R.A. No. 9165 and Robbery before this Honorable Court;

    2. The Honorable Court has rendered decisions in the Two Criminal


    Information. In its decision dated December 14, 2018, the Honorable Court
    dismissed the criminal information for Violation of Section 11 of R.A. No. 9165.
    Likewise, the Honorable Court acquitted the accused/movant in its decision
    dated June 14, 2019. The decisions of the Honorable Court in the two criminal
    information have attained finality. (Copy of the Decisions of the Honorable Court
    for Violation of Section 11 of R.A. No. 9165 and for Robbery are herewith
    attached as Annex “A” and “B” respectively);

    3. One of the evidence submitted during the Inquest Proceeding for the
    two cases is a RUSI Motorcycle, color blue, without plate number, bearing
    Chasis No.*LB2XG86DHE6001754* and Engine No. 150FMG*E6GOO1754*
    registered under Rosanna F. Bauit. (Copy of the Certificate of Registration and
    Original Receipt are hereto attached as Annexes “C” and “D”, respectively);

    4. Rosanna F. Bauit, who was issued the Original Receipt and Certification
    of Registration of the subject motorcycle has longtime surrendered the said
    motorcycle to LUZON RAM CYCLES INCORPORATED (LRCI) for failure to pay
    the remaining amortization dues;
    5. Sheril G. Monsayac, the wife of the movant acquired the subject motor
    vehicle from LUZON RAM CYCLES INCORPORATED (LRCI) by way of
    Conditional Sale. Sheril G.Monsayac will be issued the Deed of Absolute Sale
    upon full payment of the purchased price of the said subject motorcycle;

    6. At present, said subject motorcycle is impounded at PNP Station, Jones,


    Isabela as evidenced by a Certification issued by Chief of Police of PNP Jones,
    Isabela dated January 29, 2019, copy of which is hereto attached as Annex “E”;

    7. Movant desires that the subject motorcycle be released considering the


    present state of the motor vehicle results in its unwanted deterioration as it is
    being exposed to excruciating heat of the summer sun, much more, surreptitious
    removal of its parts as it is merely parked outside the police station and open to
    any passersby; thereby rendering it almost unserviceable and to the detriment of
    the movant. Further, as stated above, the cases have attained finality.

    PRAYER

    WHEREFORE, on the basis of the foregoing, it is so respectfully prayed of


    the Honorable Court that the foregoing Motion be favorably granted and to direct
    the Chief of Police of PNP Jones, Isabela to immediately release the subject
    motorcycle to herein movant as the lawful co-owner upon presentation of the
    documents evidencing ownership.

    Other reliefs just and equitable under the foregoing are likewise prayed for.

    Echague, Isabela. September 10, 2019.

    ERICSON M. MONSAYAC
    Movant

    The Branch Clerk of Court


    Branch 24, RTC,
    Echague, Isabela

    Please submit the foregoing Pleadings immediately upon receipt hereof for the
    favorable consideration of the Honorable Court without further oral arguments. Thank
    you.

    ERICSON M. MONSAYAC

    Copy furnished (personal service)

    THE HONORABLE PUBLIC PROSECUTOR


    Office of the Provincial Prosecutor
    Echague, Isabela

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