Province of Capiz REGIONAL TRIAL COURT OFFICE OF THE EXECUTIVE JUDGE City of Roxas
IN RE: IN THE MATTER OF
THE ISSUANCE OF A WRIT OF HABEAS CORPUS OF MAELYN ARROJADO
MAELYN ARROJADO, S.P. No.:
Petitioner, FOR: ISSUANCE OF A WRIT OF HABEAS CORPUS -versus-
ST. ANTHONY COLLEGE
OF ROXAS CITY, INC. (HOSPITAL), Respondent. x------------------------------------------------------------------------x
URGENT MOTION TO CONDUCT
SPECIAL RAFFLE PETITIONER MAELYN ARROJADO, by and through the undersigned counsel, unto this Honorable Court most respectfully files this Urgent Motion to Conduct Special Raffl e and further states that:
1. Petitioner is currently being confined at Room 221
of the St. Anthony College of Roxas City, Inc. (Hospital) located at San Roque Ext. St., Roxas City, Capiz. Due to an unpaid hospital bill, she is not allowed to leave from the Hospital since she received a Discharge Instruction from her attending physician on 16 April 2019 effectively curtailing her freedom of movement and continuously depriving her of her liberty without due process of law;
2. Petitioner, thus file a Petition for the Issuance of a
Writ of Habeas Corpus as a remedy for person deprived of liberty not under any lawful process and is continuously being illegal detained; 2
3. In view of the urgency of such Petition, there is a
need to request for the Conduct of Special Raffl e considering that the next Regular Conduct of Raffl e of the cases will be held on May 2019;
WHEREFORE, premises considered, it is most
respectfully prayed that the Offi ce of the Honorable Executive Judge conduct a Special Raffl e due to the urgency of the herein petition.
All other reliefs as are just and equitable are
likewise prayed for.
City of Roxas, 26 April 2019.
For the Petitioner,
DELA PIEZA-LAYO and TIDONG LAW
OFFICE Inzo Arnaldo St., Roxas City
By:
CHRISTIAN BRYANN G. TIDONG
Counsel for the Petitioner Roll No. 67286 PTR No. 5800366/12-13-17 IBP No. 039000/6-07-18 MCLE Compliance No VI-0007004/ 21-03-18 09278740253
REQUEST FOR AND NOTICE OF HEARING
ATTY. SHARMEN GALLENERO- BILLONES
Branch Clerk of Court OFFICE OF THE EXECUTIVE JUDGE Regional Trial Court- BRANCH 18
Please submit the foregoing Urgent Motion to
Conduct Special Raffle for consideration and approval of the Honorable Court immediately upon receipt hereof sans oral argument. 3