Republic of the Philippines

Department of Justice
OFFICE OF THE CITY PROSECUTOR
Pagadian City
-oOo-
PSUPT. ALVIN P. SAGUBAN, IX-05-INQ-18E-00043
Complainant.
- versus - - for -

ARNEL JOE V. ARCOY, Violations of R.A. 10591, R.A. 9516

Respondent. and Comelec Gun Ban
x-------------------------------------x

MOTION FOR RELEASE OF EVIDENCE

(CIGARETTES)

The MOVANT, in the above-entitled case through the Office of the City
Prosecutor, most respectfully states:

1. Herein the movant Arnel Joe V. Arcoy is the owner of Eighty Four (84)
Reams of Fort cigarette, Twenty Four (24) Reams of Mighty Green cigarette,
Thirty Nine (39) Reams of Mighty Red cigarette, and Sixty One (61) Reams
of Union cigarette;
2. The afore-described pieces of evidence are presently under the custody of the
City Prosecution Office, Pagadian City;

3. The movant wanted to get all the evidence as the case was dismissed as per
resolution dated May 5, 2018;

4. For purposes hereof, movant hereby respectfully tenders this instant formal
motion to possibly secure an order thereby directing the return of the subject
evidence to herein movant momentarily at least;

5. The instant motion is never intended to cause prejudice to any individual

office or entity. Neither is the instant motion in pursuit of any uncalled for
purpose save for the reason as aforementioned;

6. The movant hereby submits to whatever terms and conditions that this
Honorable Office would impose;

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Office through the handling Public Prosecutor that the subject evidence be
ordered released in favor of herein movant Arnel Joe V. Arcoy.

Such other reliefs and remedies just and equitable in the premises are likewise
prayed for.

Pagadian City, Zamboanga del Sur, July 01, 2020.

ARNEL JOE V. ARCOY

 Republic of the Philippines
Department of Justice
OFFICE OF THE CITY PROSECUTOR
Pagadian City
-oOo-
RICO MAGLANAT MACALANGAN, IX-05-INQ-21A-00007
Complainant.

- versus - - for -

HAIRODIN HABDULA SULAIMAN, VIOLATION OF R.A. 10883

Respondent.
x------------------------------------------------x

MOTION FOR RELEASE OF VEHICLE

The MOVANT, in the above-entitled case through the Office of the City
Prosecutor, most respectfully states:

1. Herein the movant Rico Maglanat Macalangan is the lawful owner of a Single
Motorcycle by virtue of a Deed of Sale, more particularly described as follows:

MAKE : HONDA
CHASSIS/SERIAL NO. : KPY10-024004741
ENGINE NO. : CFT110mE-8004741
PLATE NO. : JN2621
YEAR MODEL : 2004
COLOR : RED
BODY TYPE : MC

2. The afore-described vehicle is presently under the custody of the City

Prosecution Office, Pagadian City;

3. The movant wanted to preserve the condition of the subject vehicle under his
own personal care, custody and possession as the same is property so important
to him and he believed it can properly be taken cared of if its custody be revert
back to him;

4. For purposes hereof, movant hereby respectfully tenders this instant formal
motion to possibly secure an order thereby directing the return of the subject
vehicle to herein movant momentarily at least;

5. The instant motion is never intended to cause prejudice to any individual office
or entity. Neither is the instant motion in pursuit of any uncalled for purpose
save for the reason as aforementioned;

6. Should herein prayer be favorably acted upon by this Honorable Office, herein
movant hereby undertakes to readily bring before this Honorable Court the
subject vehicle at anytime should the need arise and should this Honorable
 Office on the court so require. Herein movant hereby likewise undertakes never
to dispose of the same and to preserve the condition thereof while under his
personal custody;

7. The movant hereby submits to whatever terms and conditions that this
Honorable Office would impose;

8. Hereto attached as Annex “A” is the Affidavit of Undertaking executed by the

movant Rico M. Macalangan.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Office through the handling Public Prosecutor that the subject vehicle be
ordered released in favor of herein movant Rico M. Macalangan.

Such other reliefs and remedies just and equitable in the premises are likewise
prayed for.

Pagadian City, Zamboanga del Sur, January 11, 2021.

RICO M. MACALANGAN
 Republic of the Philippines
Department of Justice
OFFICE OF THE CITY PROSECUTOR
Pagadian City
-oOo-
PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 14987-2K20
Complainant.
- versus - - for –

JIFFREY HAMDANI ALBANI, Violation of Section 145 of RA 8424 in

Respondent. relation to Section 254 as amended by RA
10963
x-------------------------------------x

MOTION FOR RELEASE OF VEHICLE

The MOVANT, in the above-entitled case through the Office of the City
Prosecutor, most respectfully states:

9. Herein the movant Denhar S. Palahuddin is the owner of MITSUBISHI TRUCK

by virtue of a Deed of Sale executed by Jannette Baya Lumacang, more
particularly described as follows:
MAKE : MITSUBISHI
SERIES : CANTER
CHASSIS No. : FB51AB-551422
ENGINE No. : 4M40-CX5856
PLATE No. : MAD5592

10. The afore-described vehicle is presently under the custody of the City Prosecution
Office, Pagadian City;

11. The movant wanted to preserve the condition of the subject vehicle under his own
personal care, custody and possession as the same is property so important to him
and he believed it can properly be taken cared of if its custody be revert back to
him;

12. For purposes hereof, movant hereby respectfully tenders this instant formal motion
to possibly secure an order thereby directing the return of the subject vehicle to
herein movant momentarily at least;

13. The instant motion is never intended to cause prejudice to any individual office or
entity. Neither is the instant motion in pursuit of any uncalled for purpose save for
the reason as aforementioned;
 14. Should herein prayer be favorably acted upon by this Honorable Office, herein
movant hereby undertakes to readily bring before this Honorable Court the subject
vehicle at anytime should the need arise and should this Honorable Office on the
court so require. Herein movant hereby likewise undertakes never to dispose of the
same and to preserve the condition thereof while under his personal custody;

15. The movant hereby submits to whatever terms and conditions that this Honorable
Office would impose;

16. Hereto attached as Annex “A” is the Affidavit of Undertaking executed by the
movant Denhar S. Palahuddin.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Office through the handling Public Prosecutor that the subject vehicle be
ordered released in favor of herein movant Denhar S. Palahuddin.

Such other reliefs and remedies just and equitable in the premises are likewise
prayed for.

Pagadian City, Zamboanga del Sur, June 01, 2020.

DENHAR S. PALAHUDDIN
 Republic of the Philippines
Department of Justice
OFFICE OF THE CITY PROSECUTOR
Pagadian City
-oOo-

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 15242-

2K20
Complainant. IX-05-INQ-20J-00187
- versus - - for -

MUNAR BADARI y PARANTIS, Violation of RA 10963 in

DADA SOLAIMAN ADO, Relation to Section 145 of
R.A.8424
AL DASI BAKIL JUHAILI,
SAKIB MARID SAYYADI,
ALKABID J. JUMDAIN,
ALFAHAD Y. PUSTAHAN
ABDULRAJIK FARUK HALAMAN,
Respondents.
x--------------------------------------------x

MOTION FOR RELEASE OF FISHING BOAT

The MOVANT, in the above-entitled case through the Office of the City
Prosecutor, most respectfully states:

1. Herein the movant Farouk M. Abdurajik is the registered owner of FISHING

BOAT, more particularly described as follows:
NAME OF VESSEL : PB Farsima
TYPE OF SERVICE : FISHING
YEAR BUILT : 2020
ENGINE MAKE : YAMAHA
 OFFICIAL No. : BARMM7416-10-136-20A
PLACE BUILT : Labuan, Zamboanga City

2. The afore-described FISHING BOAT is presently under the custody of the

City Prosecution Office, Pagadian City;

3. The movant wanted to preserve the condition of the subject FISHING BOAT
under his own personal care, custody and possession as the same is property
so important to him and he believed it can properly be taken cared of if its
custody be revert back to him;

4. For purposes hereof, movant hereby respectfully tenders this instant formal
motion to possibly secure an order thereby directing the return of the subject
FISHING BOAT to herein movant momentarily at least;

5. The instant motion is never intended to cause prejudice to any individual

office or entity. Neither is the instant motion in pursuit of any uncalled for
purpose save for the reason as aforementioned;

6. Should herein prayer be favorably acted upon by this Honorable Office,

herein movant hereby undertakes to readily bring before this Honorable Court
the subject FISHING BOAT at anytime should the need arise and should this
Honorable Office on the court so require. Herein movant hereby likewise
undertakes never to dispose of the same and to preserve the condition thereof
while under his personal custody;

7. The movant hereby submits to whatever terms and conditions that this
Honorable Office would impose;

8. Hereto attached as Annex “A” is the Affidavit of Undertaking executed by the

movant Farouk M. Abdurajik.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Office through the handling Public Prosecutor that the subject FISHING
BOAT be ordered released in favor of herein movant Farouk M. Abdurajik.

Such other reliefs and remedies just and equitable in the premises are likewise
prayed for.

Pagadian City, Zamboanga del Sur, October 19, 2020.

FAROUK M. ABDURAJIK
 Republic of the Philippines
Department of Justice
OFFICE OF THE CITY PROSECUTOR
Pagadian City
-oOo-

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 15242-

2K20
Complainant. IX-05-INQ-20J-00187
- versus - - for -

MUNAR BADARI y PARANTIS, Violation of RA 10963 in

DADA SOLAIMAN ADO, Relation to Section 145 of
R.A.8424
AL DASI BAKIL JUHAILI,
SAKIB MARID SAYYADI,
ALKABID J. JUMDAIN,
ALFAHAD Y. PUSTAHAN
ABDULRAJIK FARUK HALAMAN,
Respondents.
x--------------------------------------------x
 MOTION FOR RELEASE OF VEHICLE

The MOVANT, in the above-entitled case through the Office of the City
Prosecutor, most respectfully states:

1. Herein the movant GEMINSIL A. RIDZMAR is the registered owner of

Izusu ELF Truck vehicle, more particularly described as follows:
MAKE : IZUSU
SERIES : ELF
CHASSIS No. : NPR71L-7413727
ENGINE No. : 4HG1-502968
PLATE No. : MAK4799
FUEL : DIESEL
YEAR MODEL : 2017
COLOR : Green/Black

2. The afore-described vehicle is presently under the custody of the City

Prosecution
Office, Pagadian City;

3. The movant wanted to preserve the condition of the subject vehicle under his
own personal care, custody and possession as the same is property so
important to him and he believed it can properly be taken cared of if its
custody be revert back to him;

4. For purposes hereof, movant hereby respectfully tenders this instant formal
motion to possibly secure an order thereby directing the return of the subject
vehicle to herein movant momentarily at least;

5. The instant motion is never intended to cause prejudice to any individual

office or entity. Neither is the instant motion in pursuit of any uncalled for
purpose save for the reason as aforementioned;

6. Should herein prayer be favorably acted upon by this Honorable Office,

herein movant hereby undertakes to readily bring before this Honorable Court
the subject vehicle at anytime should the need arise and should this Honorable
Office on the court so require. Herein movant hereby likewise undertakes
never to dispose of the same and to preserve the condition thereof while under
his personal custody;

7. The movant hereby submits to whatever terms and conditions that this
Honorable Office would impose;

8. Hereto attached as Annex “A” is the Affidavit of Undertaking executed by the

movant GEMINSIL A. RIDZMAR.

PRAYER
 WHEREFORE, premises considered, it is most respectfully prayed of this
Honorable Office through the handling Public Prosecutor that the subject vehicle be
ordered released in favor of herein movant GEMINSIL A. RIDZMAR.

Such other reliefs and remedies just and equitable in the premises are likewise
prayed for.

Pagadian City, Zamboanga del Sur, October 19, 2020.

GEMINSIL A. RIDZMAR