REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

11th Judicial Region
Davao City
BRANCH 6

CHRISTINE A. DELA CRUZ ,

Petitioner S.P. No. ___________
- versus- For: WRIT OF HABEAS
CORPUS

MARTHA K. AGONCILLO,
Respondent
x-------------------x

MOTION FOR LEAVE TO AMEND PETITION

PETITIONER, through undersigned counsel and to this

Honorable Court most respectfully states:

1. That she filed the above-entitled petition dated March

6, 2020 on March 10, 2020;

2. That the petitioner inadvertently failed to include other

matters in support of her case; It is necessary on the part of the
petitioner to amend her petition in compliance with the order of the
Court dated April 10, 2020.

3. That Petitioner just went home recently from Canada in

order to file the Petition herself;

4. That the filing of this amendment is not to delay the

speedy disposition of the above-entitled case;

5. Petitioner had attached hereto the amended petition

for the consideration of the Honorable Court.

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Court to admit this Amended Petition.

Petitioner further prays for other relief just and equitable under
premises.
 RESPECTFULLY SUBMITTED. _______________ March 9, 2017.

Sgd.
ATTY. STEPHANIE M. SANTOALLA
Counsel for the Plaintiff
IBP NO. 071717, 12/12/19, Davao City
PTR NO. 071717, 12/12/19, Davao City
ROLL ATTORNEY NO. 11077
MCLE Comp. No. IV-0004785, 3/2/19
Doors 5 & 6, Tropicana Building,
J.P. Laurel Avenue, Lanang, Davao City

Copy Furnished: (Personal Service)

MARTHA K. AGONCILLO
Lot 4, Block 7, Phase 9-A
GSIS, Matina, Davao City

ATTY. FELICIDAD R. FUENTES

Door 7, ABC Building, Damosa
Complex, Lanang, Davao City
 NOTICE AND SETTING

THE CLERK OF COURT

REGIONAL TRIAL COURT
11th Judicial Region
Branch 6
_________________

Sir/Madam:

Please submit the foregoing motion to amended complaint to

set the date of hearing and approval of the Honorable Court May 17,
2020 at eight o’clock in the morning without need of any argument.

Sgd.
ATTY. STEPHANIE M. SANTOALLA
Counsel for the Plaintiff
IBP NO. 071717, 12/12/19, Davao City
PTR NO. 071717, 12/12/19, Davao City
ROLL ATTORNEY NO. 11077
MCLE Comp. No. IV-0004785, 3/2/19
Doors 5 & 6, Tropicana Building,
J.P. Laurel Avenue, Lanang, Davao City