Republic of the Philippines

Fourth Judicial Region

REGIONAL TRIAL COURT
Branch 19
Bacoor City, Cavite

Laging Iniiwan y Umalis,

Petitioner,
SPEC. PROC. CASE NO.
For: Habeas Corpus
-versus-

Loloy Iniiwan y itrimitida

and Lola Intrimitida
Respondents.
x-------------------------------------------------x

PETITION

COMES NOW, the Petitioner, by the undersigned

counsel, and unto this Honorable Court respectfully
represents:

1. Petitioner Laging Iniiiwan is of legal age, married to

respondent, and resident of Kenssington 17 Blck 12 Lot 9,
Lancaster City Brgy. Navarro, General Trias, Cavite.

2. Respondent Loloy Iniiwan is of legal age and resident

of Blk 6 Lot 5 Palermo St. Villa Lessandra Camella Homes,
Bacoor City. Respondent Geldelina D. Abundo is the mother
of Loy D. Abundo, of legal age and resides in the same
address.

3. Petitioner is the mother and respondent Laging iniiwan

Abundo is the father of Bsatang Iniiwan, four years old. Under
Article 213 of the Family Code of the Philippines no child
under seven years of age shall be separated from the mother
unless the court finds compelling reasons to order otherwise.

(Copies of the Marriage Certificate and Certificate of

Live Birth are hereto attached as Annexes “A” and “B”)

4. Batang Iniiwan is presently in the custody of

respondents who abducted her and until now restrains her
liberty. Respondents had since 1 June 2017 concealed
Batang Iniiwan and unlawfully withheld from petitioner of her
rightful custody of her child.

5. Despite demands, respondents refuse and

continuously refuse to turn over the custody of the Batang
Iniiwan to the petitioner.

6. WHEREFORE, it is respectfully prayed that an order be

issued to respondents to bring the minor Batang Iniiwan to this
Honorable Court at the hour and date to be set by this
Honorable court, and thereafter that the custody of the minor
Chinchin be turned over to the petitioner as a matter of right.

Other reliefs just and equitable are likewise prayed for.

Most respectfully submitted.

Manila to Bacoor City, 11 September 2017.

Celestino Pascual and Rocha Law Firm

Counsel for Petitioner
Unit No. 302, Mario Co Bldg., No 1945
M. Adriatico St., Malate, Manila

By:

Atty. Charlie DC Pascual

Roll No. 61297
IBP No. 105597 1/4/17
PTR No. 1061692 1/4/2017
MCLE Compliance No. V-0004479
Mobile No. 09988658919

VERIFICATION AND CERTIFICATION AGAINST

 FORUM- SHOPPING

I, Laging Iniiwan , of legal age, married and resident of

Kessington 17 Blck 12 Lot 9, Lancaster City Bargy. Navarro,
General Trias, Cavite under oath declare, that:

I am the petitioner in the above-entitled case; I have

caused the preparation of the foregoing Petition for Habeas
Corpus and I have read the same and the contents of which
are true and correct of our own knowledge and/or on the
basis of authentic documents.

Except for the pending case before the Regional Trial

Court Branch 19 of the Province of Cavite entitled Loy Iniiwan
and Lola Intirmitida, petitioners v. LAging Iniiwan, respondent,,
for Custody of Minor, I have not commenced any action or
filed any claim involving the same issues in any court, tribunal
or quasi-judicial agency and, to the best of my knowledge, no
such other action or claim is pending therein; that if there is
such other pending action or claim pending therein, I
undertake to make a complete statement of the present
status thereof, and if I should thereafter learn the same or
similar action or claim has been filed or is pending, I shall duly
report that fact within five (5) days therefrom to the
court/tribunal wherein this petition has been filed.

IN WITNESS WHEREOF, I have hereunto set my hands

this _________________, at ______________________.

Laging Iniiwan,
Affiant-Petitioner

Republic of the Philippines)

____________________) SS

SUBSCRIBED AND SWORN TO BEFORE ME This __________________

at _____________________, Affiants exhibiting me their competent
respective evidence of identity ___________________________________,
issued on ___________________________ at __________________________.

Doc No.
Page No.
Book No.
Series of 2017