Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch IV
City of Manila

JOSE MARI SISON

Petitioner,
GR No. 917452
For: Writ of Habeas Data

-versus-

GEN. AMADO PALPARAN

Respondent.

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PETITION FOR WRIT OF HABEAS DATA

1. This is a petition for the writ of habeas data filed under A.M. No. 08-1-16-

SC, also known as the Rule on the Writ of Habeas Data to require the

respondent to destroy, any official or unofficial reports pertaining to petitioner

covering but not limited to intelligence reports, operation reports and provost

marshal reports prior to, during and subsequent to December 26, 2015.

2. Petitioner respectfully submits that respondent has obtained the information

through the employment of tactical interrogation and torture heavily causing

trauma and depression and fear for her life;

3. This act or omission of respondent to comply with petitioner's demand is a

violation of, or poses a threat of violation to, petitioner's right to privacy in

life, liberty and security.

4. In view of the foregoing, petitioner brings this petition before this

Honorable Court praying that the respondent be required to cause the

immediate production of the information requested so that the same may be

revealed to petitioner for proper updating, rectification or, in the alternative,

for its suppression or destruction, whatever may be necessary to protect

petitioner's privacy.

5. Finally, petitioner respectfully submits that he is an indigent person and

prays that this Honorable Court exempt him from docket and other legal fees

in this case, subject to the submission of proof of his indigency within fifteen

days from the filing of this petition.

PRAYER

WHEREFORE, petitioner prays that this Honorable Court give due course

to this petition and issue the writ of habeas data and rule, as follows:

1. Upon the filing of the petition, ENJOIN respondent from disseminating the

information;
2. Upon notice and hearing, ORDER respondent to:

a. Correct, suppress or destroy the information found in the above-mentioned

diary, whatever may be applicable as determined by this Honorable Court;

and

b. Rectify the damage caused to petitioner's reputation by making a public

apology to petitioner, which shall be circulated in the manner and to such

persons as the petitioner may deem appropriate.

Other reliefs just and equitable under the premises are likewise prayed for.

Biñan City, Philippines, this 21st day of March 2016

Atty. Michelle A. Vale Cruz

Appointment No. 1028
Roll of Attorney No. 201528
PTR No. 5462
IBP No. 58726
Office Address: Vale Cruz Olives & Associates, Legaspi Village, Makati
Email Address michellevalecruz@gmail.com
Contact No. 09999999999
MCLE Compliance No. 667
 VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING

I, JOSE MARI SISON, of legal age, after having been duly sworn in

accordance with law, depose and state that:

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true and

correct of my personal knowledge and/or 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;

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.

JOSE MARI SISON

Affiant
 SUBSCRIBED AND SWORN to before me this 21ST day of March

2016 in Biñan, Laguna affiant exhibiting to me his Community Tax

Certificate No. 12234 issued on September 29, 2016 at in Cavite City.

Doc. No.___________; Angela Angeles

Page No.___________; NOTARY PUBLIC for Manila
Book No.__________; Commission Serial No.______
Series of 2016. Until December 31, 2016
Roll of Attorney_______
IBP No.________
PTR No. ___