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Republic of the Philippines

REGIONAL TRIAL COURT

Cotabato city

IN THE MATTER OF ADOPTION OF S.P. No. 0001


MINOR RAZUL KIRAM ALFONSO IBRAHIM For: Adoption
AND CHANGE OF NAME TO
JERICHO ROSALES HEUSAFF

SPS. ERWANN HEUSAFF &


ANNE CURTIS-HEUSAFF,
petitioners,
x-------------------------------------------------------------x

PETITION FOR ADOPTION

PETITIONERS, through the undersigned counsel and to


this Honorable Court, most respectfully state that:

1. The petitioners are both of legal age, Filipinos,


married to each other, and are residents of Macapagal Street,
Cotabato City where they may be served with notices,
summons, orders, and other court processes;

2. They have no legitimate children or descendants


and hereby sought to jointly adopt the minor Razul Kiram
Alfonso Ibrahim, male, five (5) years of age, Filipino, and
likewise resident of Macapagal Street, Cotabato city;

3. The petitioners were married on May 08, 1996.


This is evidenced by their “certificate of marriage”, a copy of
which is attached herein as “Annex A”;

4. The said minor’s parents, Angel Curtis and Luis


Ibrahim, were never married to each other. They were
petitioners’ neighbors;

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5. Razul Kiram’s mother, Angel Curtis, is petitioner Anne
Curtis-Heusaff’s cousin and had lived with them after the
death of the minor’s father, Luis;

6. The minor’s father, Luis Ibrahim, died in a car accident on


December 26, 2012. A copy of Luis’ death certificate is attached hereto as
Annexed B.

7. The minor’s mother abandoned him and has not been


heard of since deserting him on July 22, 2014. All possible
efforts to contact Angel have been exhausted but to no avail.

8. Ever since Angel abandoned the child, the petitioners


have taken care of Razul Kiram;

9. Petitioners are in possession of full civil capacity and


legal rights; of good moral character; has not been convicted of
any crime involving moral turpitude; physically, financially,
emotionally and psychologically capable of caring for Razul
Kiram; at least sixteen (16) years older than Razul Kiram;
capable to maintain, care for, educate, and support Razul
Kiram in keeping with the means of the family; and physically
healthy. Petitioner Erwann earns his income by working as a
government employee. His wife, Juana, is likewise gainfully
employed with the same. Copies of petitioners’ police and NBI
clearances are attached as Annex “C” and “D”; Income Tax
Return is attached as Annex “E”. The Birth Certificate of
Petitioners are attached as Annexes “F” and “G” and made an
integral part of this Petition. And petitioners’ medical
certificate is attached as Annex “H”;

9. Thus, Petitioners have all the qualifications and


none of the disqualifications under the law to adopt Razul
Kiram, who is not disqualified by law to be adopted.

10. In conjunction with this petition, Petitioners seeks


that a Certificate of Live Birth with the following details be
issued, to wit:

Name of Child: Razul Kiram Ibrahim


Sex: Male
Date of Birth: February 14, 2013
Name of Mother: Angel Curtis
Citizenship : Filipino
Religion: Roman Catholic
Occupation: N.A.

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Age at the time of this birth: 35
Name of Father Luis Ibrahim
Citizenship: Filipino
Religion: Roman Catholic
Occupation: Self-employed

PRAYER

WHEREFORE, premises considered, it is most


respectfully prayed of this Honorable Court, after due notice,
publication, and hearing to issue a decree of adoption
declaring that the minor child Razul Kiram A. Ibrahim be
considered as the legitimate child of Petitioners, and that the
Local Civil Registrar be directed to issue a Birth Certificate
with the following details:

Name of Child: Jericho Rosales Heusaff


Sex: Male
Date of Birth: February 14, 2014
Name of Mother: Anne Curtis-Heusaff
Citizenship : Filipino
Religion: Roman Catholic
Occupation: Government employee
Age at the time of this birth: 35
Name of Father Erwann Heusaff
Citizenship: Filipino
Religion: Roman Catholic
Occupation: Government employee

Other relief and remedies, just and equitable, are likewise


prayed for.

HOPE ELIZABETH S. SOBERANO


Counsel for the Petitioners
9600 Cotabato City
Tel. No. 421-6236

By:

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ATTY. Hope Elizabeth S. Soberano
Roll of Attorney’s No. 01010
PTR No.4321 Cotabato City
IBP Lifetime No.1234 Cotabato City
MCLE Compliance No.9696

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