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Republic of the Philippines

REGIONAL TRIAL COURT


7th Judicial Region
Branch ___
Mandaue City

ALEXA MAE F. APURA and,


MICHELL ANN F. APURA
Represented by their Biological Mother
MIGUELA FLORES-APURA, and
MIGUELA FLORES-APURA
Plaintiffs,

- vs - SPEC. PROC NO. ___________


For: INDIRECT CONTEMPT

ADONIS RUIZ APURA


Defendant.
X------------------------X

PETITION FOR INDIRECT CONTEMPT

COME NOW, Petitioner by undersigned counsel and, by way of a


Petition for Contempt of Court, unto this Honorable Court, most
respectfully aver that:

1. Petitioners are minors, represented herein by their mother, Miguela


F. Apura, they are all Filipino citizen, residents of Mandaue City.
However, they may be served with summons ad other processes of
this Honorable Court at Rm. 301 3/F Aniceta Bldg., Osmea Blvd.,
Cebu City;
2. Respondent, ADONIS R. APURA, is of legal age, Filipino Citizen,
married, and a resident of Keef Drive, Guadalajara, Guadalupe, Cebu
City, where he may be served with summons and other processes of
this Court;

3. This Honorable Court has issued an Order dated May 20, 2008 fixing
the amount of monthly support that respondent should provide
petitioners effective, May 2008 to FIVE THOUSAND PESOS
(P5,000.00). A copy of the Order is hereto attached as Annex A;

4. As a consequence of the Order, respondent filed a Motion for


Reconsideration on June 2, 2008 as shown by hereto attached copy of
the said Motion for Reconsideration marked as Annex B;

5. To finally resolve the matter of support pendent lite, this Honorable


Court issued a summary judgment on June 17, 2008 ordering
respondent to give petitioner a monthly support of FIVE THOUSAND
PESOS (P5,000.00) starting the month lf June, 2008. However,
despite the order, the respondent defiantly and contumaciously failed
and refused to comply with the Order;

6. The open defiance of the respondent to obey the lawful order of the
court undoubtedly constituted contempt under Sec. 21 of R.A. 9262
and the Rules of Court.
WHEREFORE, premises considered, it is most respectfully prayed of
this Honorable Court that the respondent be ordered to explain why he
should not be punished for contempt of court and that should their
explanation be found not to be satisfactory, proper punishment be meted
out in the interest of justice.

Cebu City, Philippines, July 14, 2008.

LEGAL ALTERNATIVES FOR WOMEN CENTER, INC.


Room 301 Aniceta Bldg. Osmea Blvd.
Cebu City Tel. 254-0011

By:

JOEL V. OUANO
Counsel for the Petitioner
PTR No. 361184 / Jan. 3, 2008
IBP No. 418432 Lifetime Member, Cebu City Chapter
Roll of Attorneys No. 37554
THE CLERK OF COURT
RTC _______
Mandaue City

Sir/Madam

Please set the foregoing Motion for hearing on _______, 2008 at


______ oclock in the morning.

JOEL V. OUANO

Copy Furnished

ATTY. JINEFFER B. SINGCO


Rm. 2, Mezzanine Flr., Aniceta Bldg.
Osmea Blvd., Cebu City