Republic of the Philippines

Regional Trial Court

_th Judicial Region
Branch _

MARIA DELA CRUZ

Petitioner,

-versus- SP.PROC. NO.

For: HABEAS CORPUS WITH
PRAYER FOR CUSTODY AND
PERMANENT RESTRAINING
ORDER
JUAN BATUNGBAKAL
Respondent
x------------------------------------------------------x

PETITION

PETITIONER, by counsel respectfully alleges that:

1. Petitioner Maria Dela Cruz (hereafter referred to as “Petitioner” for brevity) is of legal
age, Filipino and with residential address at Buko, Park City, Albay, Philippines.

2. Respondent Juan Batungbakal (hereafter referred to as “Respondent” for brevity) is

likewise of legal age, Filipino and with residential address at Buko, Park City, Albay,
Philippines, where he may be served with summons and processes from the Honourable
Court.

3. Petitioner and Respondent begot two children namely _________, __ years old,
having been born on ____________ and Kiddie, 6 years old, having been born on
February 21, 2012.
Copies of the children’s Certificate of Live Birth are here to attach as Annex A and B,
respectively and made integral part hereof.

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, Maria Dela Cruz, of legal age,Filipino and a resident of Buko, Park City, Albay, after
having been duly sworn in accordance with law, depose and state that:
1. That I am the Petitioner in the above-entitled case and have caused this Petition to
be prepared; that I read and understood its contents which are true and correct of my
own personal knowledge and/or based on authentic records.
2. That I have not commenced any action of proceeding involving the same issue in the
Supreme Court, the Court of Appeals or any other tribunal or agency; that to the best of
my knowledge, no such action or proceeding is pending in the Supreme Court, the
Court of Appeals or any tribunal or agency, and that, if I should learn thereafter that a
similar action or proceeding has been filed or is pending before these courts of tribunal
or agency, I undertake to report that the fact to the Court within five (5) days therefrom.

IN WITNESS WHEREFOR, I have hereunto set my hand this ____ day of

__________________,20____.

Affiant