REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
PASAY CITY
BRANCH _____

IN THE MATTER OF THE ADOPTION OF THE MINOR

JOSHIE CRUZ

SP. PROC . NO. ___

FOR: ADOPTION

SPOUSES CESAR CRUZ AND SHIELA CRUZ,

Petitioners.
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PETITION

PETITIONER, through the undersigned counsel and to this

Honorable Court, most respectfully states, THAT:

1. Petitioner Cesar Cruz (subsequently referred to as “Cesar”, for

brevity) is a Filipino, of legal age, married, and a resident of 123 Narra St.,
Pasay City. He is the paternal grandfather of the minor child sought to be
adopted. He may be served with orders, notices and other legal processes of
this Honorable Court through his undersigned counsel at the address stated
below.

2. Co-petitioner Shiela Cruz (subsequently referred to as “Shiela”,

for brevity) is a Filipino, of legal age, married, and a resident of 123 Narra
St., Pasay City. She is the paternal grandmother of the minor child sought to
be adopted. She may be served with orders, notices and other legal processes
of this Honorable Court through her undersigned counsel at the address
stated below.

3. The minor child sought to be adopted by the Petitioners is

Joshie Cruz (subsequently referred to as “Joshie” for brevity), born on
December 29, 2013 in Pasay City, to parents Princess de Leon and Juan
Cruz. He is one year and one month old as of this date of the Petition and a
resident of 123 Narra St., Pasay City. A copy of the certificate of live birth
of Joshie is attached hereto as Annex A.

4. Joshie’s mother, Princess de Leon (subsequently referred to as

“Princess” for brevity), abandoned him and has not been heard of since
deserting him on June 15, 2015. All possible efforts to contact Princess have
been exhausted but to no avail.

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 5. The minor’s father, Ernesto Cruz (subsequently referred to as
“Ernesto” for brevity), is living with the minor and the petitioners

6. The said minor’s parents, Princess de Leon and Ernesto Cruz,

were never married to each other but they lived with the petitioners upon
Joshie’s birth.

7. Ever since Princess left Joshie, Ernesto and the petitioners have
taken care of Joshie.

8. On November 13, 2015, Ernesto died because of heart attack.

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 turpitude1; physically, financially2, emotionally and
psychologically capable of caring for Joshie; at least sixteen (16) years older
than Joshie;3 capable to maintain, care for, educate, and support Joshie in
keeping with the means of the family; and physically healthy. 4 Petitioner
Cesar earns his income by working as a hospital physician. His wife, Shiela,
is likewise gainfully employed with the same hospital as a nurse.

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

disqualifications under the law to adopt Joshie, 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: Joshie Cruz

Sex: Male
Date of Birth: December 29, 2014
Name of Mother: Shiela Cruz
Citizenship : Filipino
Religion: Born Again Christian
Occupation: Nurse
Age at the time of this birth: 46
Name of Father Cesar Cruz
Citizenship: Filipino
Religion: Roman Catholic
Occupation: Hospital Physician

PRAYER
1
A copy of petitioner’s police and NBI clearances are attached as Annex C and D
2
A copy of the petitioner’s Income Tax Return is attached as Annex E
3
A copy of the Birth Certificate of Petitioners are attached as Annexes “F” and “G” and made an integral
part of this Petition.
4
A copy of petitioner’s medical certificate is attached as Annex H

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 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 Joshie Cruz 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: Joshie Cruz

Sex: Male
Date of Birth: December 29, 20154
Name of Mother: Shiela Cruz
Citizenship : Filipino
Religion: Born Again Christian
Occupation: Nurse
Age at the time of this birth: 46
Name of Father Cesar Cruz
Citizenship: Filipino
Religion: Roman Catholic
Occupation: Hospital Physician

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

THE LAW ENFOURCERS LAW FIRM

Counsel for the Petitioners
Unit 2, 2nd Floor Marco Polo Hotel
Nivel Hills
6000 Cebu City
Tel. No. (032) 221-4653

By:

ATTY. ___________________________
Roll of Attorney’s No. __________
PTR No. ____________; 10/10/2015 Cebu City
IBP Lifetime No. _________; Cebu City
MCLE Compliance No. _____________; 1/6/2014