1.

Republic of the Philippines

National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 191, Manila

IN RE: PETITION FOR HABEAS CORPUS OF MINOR AAA

SP No. 111334

JOE,
Petitioner

INDAY,
Respondent
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PETITION

PETITIONER, by counsel, respectfully states that:

1. Petitioner is the father of minor AAA, who were born Nov 7, 2011 out of the valid
marriage between petitioner and respondent INDAY.
2. The marriage failed and respondent left the family home located in Blk A Sta. Mesa
Manila together with her daughter AAA without notifying the petitioner and making them
them incommunicado and out of petitioner’s reach.
3. Being below seven (7) years of age, custody of the minors is naturally presumed to
belong to the respondent, as their mother. However her irresponsibility and carefree ways would
not guarantee that she can take care of our daughter.

WHEREFORE, petitioner respectfully prays that a writ of habeas corpus issue directing
respondent to make a return to legal authority to detain the minor children, subject of this
petition, and thereafter, present the minor children personally before the Court on or before
March 30, 2015.

Quezon City; 1 March 2015.

DDD

Counsel for the Petitioner

**Plus Verification and Cert against Forum Shopping