REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

Quezon City
Branch 5

IN THE MATTER OF THE PETITION

OF JULIANA ROSEL R. LA CHICA S.P. Case No. 12409-16
FOR A WRIT OF HABEAS CORPUS

LOILA L. LA CHICA,
Petitioner,

-versus-

JULIAN GUIEB AGUILAR

Respondent.

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PETITION FOR WRIT OF HABEAS CORPUS

COMES NOW, the petitioner LOILA L. LA CHICA, through the

undersigned counsel and unto this Honorable Court, most respectfully avers
that:

1. Petitioner LOILA L. LA CHICA is the biological mother of

JULIANA ROSEL R. LA CHICA, born on March 14, 2011 and
residing at 21 Magnolia Street Congressional Village Project 8,
Quezon City

2. Respondent JULIAN GUIEB AGUILAR is the biological father of the

child and residing at 13 Pluto Street La Vista Subdivision Barangay
San Antonio, Quezon City.

3. On February 3, 2017 the petitioner received an order for custody of

the minor child from the Regional Trial Court of Quezon City Branch
10, constituted as a Family Court and granting the respondent
visitation rights over the minor, the original copy of which is hereto
attached as Annex A

4. On March 31, 2017, respondent took JULIANA ROSEL R. LA

CHICA to Star City but did not return the JULIANA ROSEL R. LA
CHICA to the custody of LOILA L. LA CHICA.

5. On April 2, 2017, petitioner went to La Vista Subdivision Barangay

San Antonio, Quezon City but the guard of the subdivision refused the
entry of the petitioner despite showing explanation and proof of order
of custody of the minor child JULIAN LESTER R. LA CHICA from
the court.
6. Despite demand by the petitioner, respondent refuses to relinquish
custody of said child and holds the child in violation of the order
placing custody in the plaintiff.

PRAYER

WHEREFORE, petitioner prays that this Honorable Court grant her a

Writ of Habeas Corpus and order to produce the child before this Court at a
time certain, for his costs and attorneys fees and for all other just and
equitable relief.

City of Quezon, May 2, 2017.

ATTY. PABLO JAN MARC A. FILIO IV

Counsel for Petitioner
Attorneys Roll No. 92829
BP No. 2832/ Manila/ 7/2/17
PTR No. 7272 Manila 9/17/17
MCLE III Comp. No. 0018850

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )

City of Manila ) S.S.

I, LOILA L. LA CHICA, of legal age, Filipino citizen, single and resident

of 21 Magnolia Street Congressional Village Project 8, Quezon City,
after having been duly sworn to in accord Nance with law do hereby
depose and say:

1. That I am the petitioner in the above-entitled case;

2. That I have caused the preparation of the foregoing petition and have
read the allegations contained therein;

3. The allegations in the said complaint are true and correct of my own
knowledge and authentic records;

4. I hereby certify that I have not commenced any other action or

proceeding 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;

5. That if I should learn thereafter that a similar action or proceeding has

been filed or is pending, I hereby undertake to report that fact within
five (5) days therefrom to the court or agency where the original
pleading and sworn certification contemplated herein have been filed;
 6. I executed this verification/certification to attest to the truth of the
foregoing facts and to comply with the provisions of Adm. Circular
No. 04-94 of the Honorable Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

nd
2 of May 2017, in the City of Quezon.

LOILA L. LA CHICA
Passport No. EB73901
Issued on 1st of March 2016
Expired on 1st of March 2021
Issued at Pasay City

ATTY. PABLO JAN MARC A. FILIO IV

NOTARY Public For Quezon City
Commission Serial No. 9839
Until December 31, 2017
Roll of Attorney 92829
BP No. 2832/ Manila/ 7/2/17
PTR No. 7272 Manila 9/17/17

Doc No. 832;

Page No. 5;
Book No.12;
Series of 2017