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Motion To Withdraw Ramos2

The motion requests the release of a motorcycle, cellphone, and property bond that were seized from Ryan Sarona Ramos following his guilty plea and conviction. It also requests the cancellation of any annotation on the property bond's tax declaration. The accused's counsel argues that since the case is terminated, the seized items should be returned to Ramos and the property bond annotation canceled. The motion is submitted to the court for consideration and approval.

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James Decolongon
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84 views2 pages

Motion To Withdraw Ramos2

The motion requests the release of a motorcycle, cellphone, and property bond that were seized from Ryan Sarona Ramos following his guilty plea and conviction. It also requests the cancellation of any annotation on the property bond's tax declaration. The accused's counsel argues that since the case is terminated, the seized items should be returned to Ramos and the property bond annotation canceled. The motion is submitted to the court for consideration and approval.

Uploaded by

James Decolongon
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

REGIONAL TRIAL COURT


11th Judicial Region
Branch 18
Digos City, Davao del Sur

THE PEOPLE OF THE PHILIPPINES


Plaintiff, CRIM. CASE NOS. 482 (14)
and 483 (14)

-versus- FOR: VIOL. OF SEC. 5 and


SEC. 11 OF R.A. 9165

RYAN SARONA RAMOS @ RYAN,


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

MOTION TO RELEASE THE MOTORCYCLE,


CELLPHONE
AND THE PROPERTY BOND OF RYAN RAMOS WITH
PRAYER FOR THE CANCELLATION OF ITS
ANNOTATION

COMES NOW, undersigned counsel unto this Honorable Court, most


respectfully states:

That the above-entitled case was terminated upon the voluntary plea
of guilty of the accused RYAN SARONA RAMOS in the Joint Decision
promulgated by the Honorable Court on August 15, 2019;

That in view thereof, it is hereby prayed that the Motorcycle and


Cellphone taken/seized from Ryan Sarona Ramos by the Police Office and
the property bond posted for his temporary liberty, such as property
embraced under Tax Declaration No._____________ be ordered released to
said RYAN RAMOS or his authorized representative;

Further, it is hereby prayed that an Order be issued directing the City


Assessor’s Office to cause the cancellation of its annotation on the face of
the above-mentioned Tax Declaration.

Other relief just and equitable are prayed for.

Digos City, Davao del Sur, Philippines. December 10, 2020.

AMARA LAW

Page 1 of 2
Counsel for the Accused
Unit 8 2F DASURBACO Bldg.
Magsaysay-Jacinto Sts., Digos City
8002 Davao del Sur, Philippines

For the Firm:

ATTY. ANNA MARGARITA A. RAZONABLE-


MAMUAD
Roll of Attorneys 46708
MCLE COMPLIANCE NO. VI-0002745; 04-14-2022
PTR No. 8072440 issued on 01-06-20 @ Davao del Sur
IBP No. 110848 on issued on 01-18-20 @ Pasig City
Mobile No. 09561264522

NOTICE

The Clerk of Court


RTC-Br. 18
Digos City, Davao del Sur

Greetings!

Kindly submit the foregoing Motion to Release Motorcycle,


Cellphone and the Property Bond and to cancel the Annotation therein for
the consideration and approval of the Honorable Court.

ATTY. ANNA MARGARITA A. RAZONABLE-


MAMUAD

Copy furnished:

Pros. Suzette A. Gallemaso-Dalumpines


Office of the City Prosecutor
Digos City

Page 2 of 2

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