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Republic of the Philippines

REGIONAL TRIAL COURT


Third Judicial Region
Malolos City, Bulacan
Branch 83

PEOPLE OF THE PHILIPPINES,


- versus 319-M-2015

Criminal Case No.

ALBERTO H. EVANGELISTA,
Accused.
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MOTION FOR RELEASE FROM CUSTODY WITH


UNDERTAKING
Accused, unto this Honorable Court, respectfully alleges that:

1. On January 19, 2015, my Win 125 Kawasaki tricycle with plate number
AC 1921 was being driven by the accused ALBERTO H. EVANGELISTA when a
collision with another motorcycle occurred. As a result of the said incident,
the said tricycle is now under the custody and possession of Traffic
Enforcement Unit Malolos.
2. I am the owner of the said Win 125 Kawasaki tricycle with plate
number AC 1921 by virtue of a Deed of Sale I entered into with Emmanuel T.
Vasquez, Jr.
3. After having posted cash bond, Alberto H. Evangelista was ordered
released from the custody of the PNP City of Malolos Police Station, Bulacan.
4. I hereby undertake to surrender the said tricycle when so required or
ordered by the court.

WHEREFORE, premises considered, it is respectfully prayed that an


order for the release of my aforementioned motor vehicle be issued by the
court pending the determination of Alberto H. Evangelistas guilt.
Respectfully submitted.

BERNARD E. PAGADUAN
Owner

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