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Republic of the Philippines

REGIONAL TRIAL COURT


Fourth Judicial Region
Branch I
Batangas City

IN THE MATTER OF
THE ADOPTION OF THE MINOR
JINELLE MAGNO
SP. PROC . NO. ___
FOR: ADOPTION
SPOUSES JUAN MAGNO
AND CHERYLLE MAGNO, Petitioners.

X ------------------------------------------------- X

PETITION

PETITIONERS, through the undersigned counsel and to this


Honorable Court, most respectfully states, THAT:

1. Petitioners Juan Magno and Cherylle Magno are Filipinos, of


legal age, and residents of Pallocan West, Batangas City. They are the
paternal grandparents of the minor child sought to be adopted. They
may be served with orders, notices and other legal processes of this
Honorable Court through his undersigned counsel at the address stated
below.
2. The minor child sought to be adopted by the Petitioner is
Jinelle Magno (subsequently referred to as “Jinelle” for brevity), born on
October 26, 2013 in Batangas City, to parents John and Ynelle Magno.
He is five years old as of this date of the Petition and a resident of
Pallocan West, Batangas City. A copy of the certificate of live birth of
Jinelle is attached hereto as Annex “A”.

3. Jinelle’s natural parents were Overseas Filipino Workers


both working as English Instructors in Senior High Schools in South
Korea. They left Jinelle to his paternal grandparents when the child was
barely one year old. Since then petitioners are the ones who have taken
care of Jinelle;

4. It was on that fateful date of April 16, 2014 that Jinelle’s


parents became two of the victims of the Sewol Ferry Incident which
killed majority of its passengers. Jinelle’s parents were then some of the
instructors included in the educational trip supposed to be held in Jeju
Island;

5. From the time Jinelle’s parents left until now almost six
years after their death, petitioners are the ones taking care of her;

8. 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 Jinelle; at least sixteen (16) years

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older than Junrel; capable to maintain, care for, educate, and support
Junrel in keeping with the means of the family; and physically healthy.
Petitioner Juan earns his income by working as a Pediatric Surgeon. His
wife, Juana, is likewise gainfully employed with the same hospital as a
head nurse. The foregoing are evidenced by the following, respectively:
certified copies of petitioner’s police and NBI clearances are attached as
Annex “B” and “C”, certified copy of the petitioner’s Income Tax Return is
attached as Annex “D”, copy of the Birth Certificate of Petitioners are
attached as Annexes “E” and “F” and a copy of petitioner’s medical
certificate is attached as Annex “G” are made integral part of this
Petition;

9. Thus, Petitioners have all the qualifications and none of the


disqualifications under the law to adopt Jinelle, who is not disqualified
by law to be adopted. It will be for the best interest of the minor child to
be adopted by his paternal grandparents.

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: Jinelle Magno


Sex: Female
Date of Birth: February 26, 2014
Name of Mother: Ynelle Magno
Citizenship : Filipino
Religion: Roman Catholic
Occupation: English Instructor
Name of Father John Magno
Citizenship: Filipino
Religion: Roman Catholic
Occupation: English Instructor

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 Jinelle Magno
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: Jinelle Magno


Sex: Female
Date of Birth: October 26, 2014
Name of Mother: Cherylle Magno
Citizenship : Filipino
Religion: Roman Catholic
Occupation: Nurse
Age at the time of this birth: 51
Name of Father Juan Magno
Citizenship: Filipino
Religion: Roman Catholic
Occupation: Pediatric Surgeon

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Other relief and remedies, just and equitable, are likewise prayed
for.

April 12, 2020, Batangas City, Philippines.

ATTY. MARIA ACONTE


Counsel for the Petitioners
PTR No. 18909595:1-04-07:B.C.
IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97:
Pallocan West, Batangas City

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REPUBLIC OF THE PHILIPPINES)
MUNICIPALITY OF ROSARIO )S.S.
PROVINCE OF BATANGAS )

VERIFICATION AND CERTIFICATION


OF NON-FORUM SHOPPING

We, Juan and Cherylle Magno, of legal age, after having been duly
sworn in accordance with law, depose and state that:
1. We are the plaintiffs in the above-stated case;
2. We caused the preparation of the foregoing complaint;
3. We have read the contents thereof and the facts stated therein
are true and correct of my personal knowledge and/or on the
basis of copies of documents and records in my possession;
4. We 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 our 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 we 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, we undertake
to report that fact within five (5) days therefrom to this
Honorable Court.

Juan Magno Cherylle Magno


Affiant Affiant

SUBSCRIBED AND SWORN to before me this 12th day of April,


2020 at Rosario, Batangas affiant exhibiting to me his Driver’s License
with No.DOJ-01-0087.

ATTY. MARIA ACONTE


Doc. No. ; Counsel for the Plaintiff
Page No. ; PTR No. 18909595:1-04-07:B.C.
Book No. ; IBP No, 693095:1-04-07:B.C.
Series of 20__. Roll No. 42481:5-10-97:
Gualberto Ave. Poblacion A,
Rosario, Batangas

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