Professional Documents
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Petition For Habeas Corpus and Custody
Petition For Habeas Corpus and Custody
PETITION
6. Sometime at the end of 2003, the two found out that the
Respondent was pregnant. Although the Petitioner realized the
shame that the Respondent will endure as soon as the news that she
got pregnant out of wedlock comes out, Petitioner himself was
confused because he could not know for sure if he was the father of
the child, since the Respondent was dating and was having pre-
marital sex with other men at that time. Not knowing what to do, the
Respondent went back to the Philippines. Thereafter, the Petitioner,
still confused by the situation,followed and likewise came home.
10. The Respondent often leaves the children alone with little
and at times without adult supervision. The children are mere toddlers
and accidents are bound to happen when they are left alone, even for
just a brief period of time.
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youngest child, George Ringgo. However, she left their oldest
son, John Paul, with the maid inside their car, while it was
parked in front of the house of Petitioner’s mother, with the
windows closed and with no air-conditioning. For some reason,
the maid left the car, leaving John Paul, all alone inside, without
adult supervision. Thus, John Paul almost suffocated, so much
so that the child, only 2 years old at that time, was madly
banging the car in order to get out of it. It was then that the
Petitioner’s sistersaw John Paul, and opened the car finding the
child soaked in sweat and gasping for breath.
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e. The Respondent has been so neglectful and
inattentive that the teat of the feeding bottle of George RInggo
has had a huge cut for some time before it has been
discovered. This could have caused asphyxiation to a feeding
toddler because of the milk that spurts out of the huge cut. It
may even cause choking in the event that the child finally bites
off the cut teat.
11. The Respondent does not care if the children sleep or eat
on time or if they are getting enough sleep or proper nutrition. She
spends so much time chatting in the internet or watching television or
hanging out with her friends that she neglects to perform her
obligations to her children.
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them to harmful elements present in an adult environment such
as parties. Respondent also refuses to go home early from
these parties further depriving her children the much needed
rest and sleep necessary for the children’s growth and
development. She would often go home from these parties by
midnight or even past midnight.
13. Finally, the Respondent’s lack oflove and care for her
children is manifested by her failure to take time out to teach and
educate her children during their cognitive years. She would lock
herself inside the office room in the third floor so that the children
could not bother her.
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family life for that matter. She expects the children to adjust to her
lifestyle even if it means sleep deprivation, undernourishment and
poor mental and psychological growth. The environment that the
Respondent has created for her children is overly inimical to their
health and well-being that the best interests of both children are best
served if they stay with the Petitioner, with temporary visitational
rights from the Respondent.
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that since she is the mother of the children, the latter should stay only
with her.
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time he had been deprived of their company. The Honorable Court
should likewise order that the parties equally share parental authority
and custody over their minor children.
24. The Respondent has the means and the capacity to bring
the children out of the country to the extreme prejudice of, and
injustice, to herein Petitioner. It is thus prayed that the Honorable
Court immediately issue a Hold Departure Order to prevent either of
the parties from bringing the children out of the country without the
consent of the other parent and the Honorable Court.
PRAYER