Republic of the Philippines

11th Judicial Region

REGIONAL TRIAL COURT

BRANCH 8

Davao City

JANE BOONDOC
Petitioner,

Special Proceeding No. 14344

IN RE: PETITION FOR HABEAS
CORPUS OF THE MINOR
OLIVE OIL

JOHN BOONDOC
Respondent.

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

PETITION

PETITIONER, by counsel, respectfully submits that:

1. Petitioner is the mother of the minor OLIVE OIL who was born out
of the valid marriage between petitioner and respondent JOHN
BOONDOC;

2. The petitioner and respondent have been separated de facto since

2014;

3. The minor has been living with the petitioner in the house of the
latter’s mother and the minor’s maternal grandmother since the
petitioner and the respondent separated;

4. Sometime in January 2016, the respondent, unknown to the petitioner,

went to the house where the minor was residing and abducted the
latter and has kept her incommunicado and out of petitioner’s reach;

5. Being below seven (7) years of age, custody of the minor is naturally
presumed to belong to the petitioner, as her mother. Consequently,
 respondent’s refusal to allow petitioner to regain custody over the
minor is unlawful and unjustified.

WHEREFORE, petitioner respectfully prays that a Writ of Habeas

Corpus be issued directing respondent to make a return showing his legal
authority to detain the minor child, subject of this petition, and thereafter,
present the minor child personally before the Court on a date and time it
chooses.

Respectfully submitted this 2nd day of February 2020 at Davao City,

Philippines.

GRIDLIN A. MATILAC

Counsel for Petitioner

Until December 31, 2021
Attorney’s Roll No. 10772
PTR No. 7862245 B; 01-02-20; Davao City
IBP O.R. No. 024454; 01-02-20; Davao
City
REPUBLIC OF THE PHILIPPINES)
PROVINCE OF DAVAO DEL SUR) S.S
IN THE CITY OF DAVAO………..)
X…………………………………….X

VERIFICATION AND CERTIFICATION

I, JANE BOONDOC, of legal age, after having been duly sworn in
accordance with law, depose and state that:
1. I am a petitioner in the above-stated case representing the republic
of the Philippines;
2. I caused the preparation of the foregoing petition;
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 true and
authentic records.
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.

IN WITNESS WHEREOF, I have hereunto affixed my signatures this

2nd day of February 2019, at Davao City, Philippines.

                                JANE BOONDOC
Affiant
 SUBSCRIBED AND SWORN to before me in the City of Davao this
th
30 day of April 2016, by JANE BOONDOC, who has satisfactorily
proven her identity to me through his Voter’s ID issued by the COMELEC
bearing his photograph and signature and with VIN 1123-
06789J1214GJC10002-4, that he is the same person who personally signed
the foregoing document before me and acknowledged that he executed the
same.

WITNESS MY HAND AND SEAL this 2nd day of February 2020

in Davao City, Philippines.

NOTARY PUBLIC
Doc. No. 54;
Page No. 11;
Book No. 01;
Series of 2020.