Republic of the Philippines

SHARIA DISTRICT COURT

Branch 2, Sharia Judicial District
Zamboanga City
ALMUKTHAR ALI,
Plaintiff,
-versus-

CIVIL CASE NO. 00356

FATIMA HASSAN,
Defendant,

For: CUSTODY OF MINOR

x---------------------------------x

COMPLAINT
COMES NOW, the plaintiff, by the undersigned counsel and unto this
Honorable Court, most respectfully aver:
1. That plaintiff is of legal age, Filipino Muslim, and a resident of Ilian,
Marantao, Lanao del Sur while defendant is also of legal age, Filipino
Muslim and a resident of Bo. Fort, Bangon, Marawi City where she may be
served with summons.
2. That plaintiff and defendant were married on 03 April 1984 in accordance
with Islamic law, and stayed married, living as husband and wife, until 29
May 1988 when plaintiff divorced defendant by repudiating the latter in
accordance with Presidential Decree No. 1083;
3. That, during the marriage, plaintiff and defendant begot two (2) children
all of whom are now living, namely AMERAH aged 9, and HASSANAH aged
8, al surnamed ALI;
4. That, on 27 September 1992, defendant entered into a new contract of
marriage named KAREENA KAPOOR;
5. That, said children are now all above seven (7) years of age and still under
the care and custody of the defendant;
6. That, defendant has no means of income and relies entirely upon her
husband KAREENA KAPOOR for support and consequently, lacks financial
ability to raise and educate said children properly;
7. That, on several occasions, plaintiff demanded of the plaintiff to deliver
the care and custody of said children to plaintiff but defendant refused
and continues to refuse to do so without just and lawful cause; and
8. That plaintiff is the father of said children and is fully interested in their
well-being, and is financially morally and socially n a much better position
than defendant to raise and educate said children.
WHEREFORE, it is most respectfully prayed that judgement be rendered:
1. Awarding the care and custody of the two (2) children, namely, AMERAH,
aged 9; and HASSANAH aged 8, all surnamed ALI, to plaintiff without
prejudice to defendant visiting and seeing said children during such period
as this Honorable Court deems proper; and
2. Adjudging defendant to pay the costs of this suit.
Plaintiff further prays for such other reliefs deemed just and equitable under
the premises.
31 May 2015, Marawi City, Philippines.

AREANNE C. RODA
Counsel for Plaintiff
2/F, Vitug Building
Mayor Jaldon Street
Zamboanga City
IBP O.R. 00356 6/10/2000
PTR No. 2000-6/10/2000

Republic of the Philippines

SHARIA DISTRICT COURT
Branch 2, Sharia Judicial District
Zamboanga City
FATIMA HASSAN,
Plaintiff,
-versus-

CIVIL CASE NO. 00356

ALMUKTHAR ALI,
Defendant,

For: CUSTODY OF MINOR

x---------------------------------x

ANSWER
DEFENDANT, by counsel, unto this Honorable Court, respectfully alleges:
1. That defendant admits the allegations of paragraph 1, 2, 3 and 5 of the complaint;
2. That defendant specifically denies the allegations of paragraph 4 of the complaint the
truth being that her proposed marriage with KAREENA KAPOOR was not pushed
through and, defendant is at present still a divorce;
3. That defendant specifically denies the allegations of paragraph 6 of the complaint the
truth being that after divorce from plaintiff, defendant was appointed as public school
teacher and, therefore, is earning income and does not depend upon anybody for the
support of herself and their children;
4. That defendant denies the allegations of paragraph 7 of the complaint for want of
knowledge and information sufficient to form a belief thereof.
5. That defendant admits paragraph 8 of the complaint insofar as it alleges that plaintiff
is the father of said children but denies all the other parts thereof for want of
knowledge and information sufficient to form a belief thereof.
WHEREFORE, it is respectfully prayed of this Honorable Court that the complaint be
dismissed for lack of merit.
Other reliefs deemed just and equitable under the premise are also prayed for.
20 June 2013, Marawi City, Philippines.

AREANNE C.RODA
Counsel for Plaintiff
2/F, Vitug Building
Mayor Jaldon Street
Zamboanga City
IBP O.R. 00356 6/10/2000
PTR No. 2000-6/10/2000
Copy received:
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Date