REPUBLIC OF THE PHILIPPINES

Department of Justice
OFFICE OF THE CITY PROSECUTOR
Pasay City

RUFINO
Complainant,
NPS NO. ________________
-versus- For: VIOLATION OF ARTICLE 270 RPC
(FAILURE TO RETURN MINOR); &
VIOLATION OF ARTICLE 276, RPC
(KIDNAPPING AND SERIOUS
ILLEGAL
DETENTION)

MARY ANN
Respondent.
x--------------------------------------------------x

REPUBLIC OF THE PHILIPPINES)

PASAY CITY ) S.S.

MEMORANDUM

PRIVATE RESPONDENT, by counsel, to this office, in

compliance with the Resolution promulgated on 14 January
2019, a copy of which was received on 15 January 2019, most
respectfully states:

STATEMENT OF THE CASE AND FACTS

For the appreciation of this office, the private respondent

reproduces herein the pertinent facts relative to this case and
briefly states:

The instant case stemmed from the Complaint of RUFINO

against the Respondent for VIOLATION OF ARTICLE 270 OF
RPC (FAILURE TO RETURN MINOR), & VIOLATION OF
ARTILCE 276 OF RPC (KIDNAPPING AND SERIOUS ILLEGAL
DETENTION).

THE