REPUBLIC OF THE PHILIPPINES

FIRST JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 7, Baguio City
In the Matter of the Adoption of
PEPITO ALAG SANCHEZ
Proc. No.: 1007-R
FORDOMESTIC
ADOPTION
JOHN SANCHEZ,
Petitioner.
x-----------------------------------------x

Spec.

PETITION
COMES NOW, the petitioner, through the undersigned
counsel, and unto this Honorable Court, most respectfully
avers:
1. That the petitioner is a dual citizen of the Philippines
and Australia, of legal age, single, and a currently a
resident of Atok Trail, Baguio City but for the purpose of
this proceedings, he elects his Australian citizenship;
2. That the petitioner has no children or descendants and
hereby desires to adopt his nephew PEPITO ALAG
SANCHEZ, Filipino citizen, 52 years old, single, a
resident of Session Road, Baguio City, who is suffering
from severe cerebral palsy and is unable to fend for
himself, therefore, an incompetent under the law for his
inability to control his limbs making him dependent
upon someone else all his life;
3. That the parents of Pepito are now dead, and he is not
under the care of his brothers since he has been
roaming the streets of Baguio City and living off alms
while his brothers enjoy the estate left by their parents;
4. That the relatives of Pepito are the following:
a. Russell Alag Sanchez, 61 years old, his brother,
resident of Anda, Pangasinan;

b. Keith Alag Sanchez, 59 years old, his brother,

resident of Anda, Pangasinan;
c. Allan Alag Sanchez, 57 years old, his brother,
resident of Anda, Pangasinan;
d. Ben Alag Ilao Jr., 32 years old, his half-brother,
resident of 23 Aurora Hill, Baguio City;
e. Jack Alag Ilao, 29 years old, his half-brother,
resident of 23 Aurora Hill, Baguio City;
f. Michael Sanchez, 75 years old, his paternal uncle,
resident of Anda, Pangasinan; and
g. John Sanchez, 72 years old, his paternal uncle,
resident of Atok Trail, Baguio City;
5. That Pepito is the co-owner pro indiviso of a house and
lot at 23 Aurora Hill, Baguio City he inherited from his
deceased parents together with his three brothers,
covered by Transfer of Certificate of Title No. T-45678 in
the names of his deceased parents Pedro Sanchez and
Genoveva Alag;
6. That the petitioner possesses all the qualifications and
none of the disqualifications required of an alien
adopter by Section 7 of the Domestic Adoption Act of
1998, to wit: of legal age being 72 years old, in
possession of full civil capacity and legal rights, of good
moral character, has not been convicted of any crime
involving
moral
turpitude,
emotionally
and
psychologically capable of caring for Pepito, at least
sixteen (16) years older than Pepito,and Pepito is his
relative within the third degree of consanguinity;
7. That the petitioner had attended pre-adoption seminars
and counselling sessions prepared and provided by the
Department of Social Welfare and Development in
preparation for the adoption as evidenced by
certificates heretofore attached as Annex A;

8. That the petitioner, during his lifetime and beyond, will

be able to financially support Pepito as when Pepito
becomes his legitimate son and becomes an Australian
citizen, he will be entitled support from the Australian
government due to his condition, and he also may avail
of survivorship benefits in case of petitioners demise;
9. That Pepito, though suffering from severe cerebral
palsy, fully understands the consequences of the
adoption and was able to communicate his eager
consent to be adopted by petitioner which was heard
and now witnessed by two disinterested persons from
the Department of Social Welfare and Development
with their sworn affidavits heretofore attached as
Annexes B and C;
10.
That petitioner only wants to provide love, care,
understanding, and security to Pepito that his other
relatives have failed to give and petitioner wants to
uphold and make paramount the best interests of
Pepito now and in the future which are also the policies
of the Domestic Adoption Act of 1998.
WHEREFORE, the petitioner respectfully prays that after
due notice and hearing, judgment be rendered declaring
PEPITO ALAG SANCHEZ for all intents and purposes, the
legitimate child of petitioner JOHN SANCHEZ.
Baguio City, Philippines, this 28thday of February 2014.

ATTY. MARIUS F. PONTMERCI

Counsel for the Petitioner
3F La Azotea Bldg., Session Road, Baguio City
(074) 422-0987
mfpontmerci@gmail.com
PTR No. 1999910/Baguio City/01-02-14
Roll of Atty. No. 81319/05-05-13
IBP OR No. 692876/Baguio-Benguet/01-02-14
MCLE Compliance No. IV-99080/04-22-13

REPUBLIC OF THE PHILIPPINES}

CITY OF BAGUIO
} S.S.
x ---------------------------------------------- x
VERIFICATION AND CERTIFICATION OF NON-FORUM
SHOPPING
I, JOHN SANCHEZ,of legal age, widower, Filipino
citizen, and resident of Atok Trail, Baguio City, Philippines
after having been duly sworn in accordance with law, depose
and state that:
1. I am the petitioner in the above-entitled case;
2. I have caused the preparation and the filing of the
foregoing petition;
3. I have read the contents thereof and the facts stated
therein are true and correct of my personal knowledge
and on the basis of copies of documents and records in
my possession;

4. I have not commenced any other action or proceeding

involving the same issues in the Supreme Court, the
Court of Appeals, or any other tribunal or agency;
5. To the best of my knowledge and belief, no such action
or proceeding is pending in the Supreme Court, the
Court of Appeals, or any other tribunal or agency; and
6. If I should thereafter learn that a similar action or
proceeding has been filed or is pending before the
Supreme Court, the Court of Appeals, or any other
tribunal or agency, I undertake to report that fact within
five (5) days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto set my hand

this 28thday of February 2014, at Baguio City, Philippines.
JOHN SANCHEZ
Affiant
SUBSCRIBED AND SWORN to before me, in the City
of Baguio, Philippines, this 28thday of February 2014, by
JOHN SANCHEZ,who is personally known to me, who is the
same person who personally signed before me the foregoing
document.
ATTY. JUAN DE LA CRUZ JR.
Notary Public
Until December 31, 2014

Doc. No.
86;
Page No. 18;
Book No.
I;
Series of 2014

100A Session Road, Baguio City

(074) 422-1234
juandelacruzjr@yahoo.com
PTR No. 1928374/Baguio City/01-02-14
Roll of Atty. No. 67548/05-18-10
IBP OR No. 739281/Baguio-Benguet/0102-14
MCLE Compliance No. IV-90210/04-2213
Commission Serial No. 01-NC-11 (R)

Copy Furnished:

OFFICE OF THE LOCAL CIVIL REGISTRAR

T. Alonzo Street, New Lucban, Baguio City

NATIONAL STATISTICS OFFICE

141 Abanao Extension, Baguio City

OFFICE OF THE CITY PROSECUTOR

Justice Hall, Baguio City

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo Street, Legaspi Village, Makati City