Republic of the Philippines
THE HONORABLE CITY PROSECUTOR
PARAÑAQUE CITY
To: The Honorable City Prosecutor
6th Floor New City Hall Building
SAV 1 Parañaque City
Re: XV-12-INQ-20-1018
MOTION TO RELEASE EVIDENCE
I, RONARIO ROGELIO , to the Honorable Prosecutor respectfully states:
That on or about 5:20 p.m. of November 4, 2020 along Taft Avenue,
Parañaque City, Dexon DICKISON, the respondent in this complaint for THEFT
pickpocketed my cellular phone specifically described as follows: ONE (1) piece
of color black Vivo y81 with casing;
That said cellular phone is now in the custody of the arresting officers PCpl
Alvin Chipy, member of the Philippine National Police and presently assigned at
Baclaran Sub Station 1 of the Station Investigation and Detective Management
Branch of Parañaque City Police Station, recovered right after the arrest without a
warrant of the herein respondent;
That said cellular phone is essential to my work as security guard as it is the
only means of communication I have with my employer, family and friends;
That I promise to present said phone whenever requested by the police
officers, the Honorable Prosecutor, and the Honorable Court, when requested.
PRAYER
WHEREFORE, premises considered, it is respectfully prayed that the Order
be issued directing PCpl Alvin Chipy to turn over the possession of the said
cellular phone to me, complainant ROGELIO DICKISON, or my duly
authorized representatives in the interest of justice.
Parañaque City, 11 November 2020.
ROGELIO DICKISON
Private Complainant