Republic of the Philippines

FIRST JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 6
La Trinidad, Benguet

PRECIOUS EDROZO,
Five (5) years of age,
Represented by her mother,
MAYUMI EDROZO, S.P. No.12345
Petitioner, For: HABEAS CORPUS

-versus-

MAKISIG EDROZO and GRAZILDA EDROZO,

Respondents.
X-------------------------------------------X

P E T I T I O N

Petitioner, represented by her mother, MAYUMI EDROZO, through her undersigned

counsel and unto this honorable court states that:

1. The petitioner is a minor, two years of age, and under the legal custody of and residing
with her mother MAYUMI EDROZO at JC-153 Pico, La Trinidad, Benguet, while the
respondents are of legal age and are residing at 74 Rimando Road, Aurora Hill, Baguio
City where they may be served with processes;

2. The petitioner is the legitimate child of MAYUMI EDROZO with the respondent
MAKISIG EDROZO;

3. Due to several attempts made by respondent MAKISIG EDROZO on the life of his wife
MAYUMI EDROZO, the parties have separated with the minor child remaining in the
custody of her mother;

4. The legal custody of the said minor, being under five years of age, is vested in MAYUMI
EDROZO;

5. On December 20, 2010, at about 2:30 in the afternoon, the respondent MAKISIG
EDROZO, resorting to ruse and trickery, absconded with the petitioner surreptitiously
leaving MAYUMI EDROZO in a mall at Magsaysay Avenue, Baguio City without
returning the said minor to the custody of their mother;

6. The petitioner, in whose behalf this application is being made, is actually restrained of
her liberty by the respondent MAKISIG EDROZO in the residence of his mother
GRAZILDA EDROZO who has knowledge that her son is continuously restraining the
petitioner;
 7. The petitioner is a child of a very delicate state of health and easily get sick without
special care and attention;

8. The petitioner has exhausted all efforts available at law, and that she has no other plain,
speedy or adequate remedy to protect her rights except by application for a writ of
Habeas Corpus.

PRAY E R

WHEREFORE, the petitioner prays that a Writ of Habeas Corpus issue out of this
Honorable Court, directed to the respondents MAKISIG EDROZO AND GRAZILDA EDROZO
commanding them to have the body of the minor, PRECIOUS EDROZO before this Court at the
time and place specified therein, and t summon the said respondents then and there to appear and
to show cause of the detention of the said petitioner, and that after due proceedings, the said
PRECIOUS EDROZO be discharged from restraint. Petitioner likewise prays for other reliefs
just and equitable.

Baguio City for La Trinidad, Benguet, 1 February 2014.

ATTY. JOSELITO AGBUGGO

Counsel for the Petitioner
Number 623 Magsaysay Avenue, Baguio City
PTR NO. 106532:01-08-2011; Baguio City
IBP NO. 56983:01-08-2011; Baguio City
ROLL NO. 56321: May 6, 2000
Baguio City

REPUBLIC OF THE PHILIPPINES }

DONE: IN THE CITY OF BAGUIO } S.S.
X ========================== X

VERIFICATION AND CERTIFICATION

AGAINST FORUM SHOPPING

I, MAYUMI EDROZO, of legal age, Filipino citizen, with postal address at Number JC-
153 Pico, La Trinidad, Benguet after having been duly sworn to in accordance with law do
hereby depose and state that;

1. I caused the preparation of this petition; that the contents thereof were duly explained
to me; that I fully understood all its contents and that the same and all the factual matters stated
therein are true and correct of my own knowledge.

2. I have not commenced any action or proceeding involving the same issue in any Court
or before any other agency or tribunal and that to the best of my knowledge, no such action or
proceeding is pending before any Court, any agency or tribunal; and if there be any; that I
undertake to inform this Honorable Court within five (5) days.

IN WITNESS WHEREOF I have hereunto set my hand this 1 st day of February 2014 at
La Trinidad, Benguet, Philippines.

MAYUMI EDROZO
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio this 1st day of February
2014 by Mayumi Edrozo, personally known to me, who is the same person who personally
signed before me the foregoing affidavit and acknowledged that she executed the same.

JO-ANNE M. VENTIGAN
Notary Public for Baguio City
Until December 31, 2014
4F La Azotea Bldg., Session Road, Baguio City
Tel No.: (074)-442-3396
Doc. No. __; PTR No. 22222; 1/07/2014; Baguio City
Page No. __;
IBP OR No: 7654321; 1/07/2014; Baguio City
Book No. I;
Series of 2014.
Roll No.: 82112; 4/08/2004
Commission No.: 74-NC-12 (R)
MCLE Compliance No.: IV-34458; 04/28/2014
TIN No: 802-112-107