Republic of the Philippines

National Capital Judicial Region

Regional Trial Court
Las Piñas City

XIAO YONGJIANG
PASSPORT NO. PROC-EF0395087
Petitioner,
vs. Case No. ___________
For: Application of
for Issuance of
Writ
of Habeas Corpus
Philippine National Police–
National Capital Region
Police Office (PNP-NCRPO)
and Anti-Cyber Crime Group
(PNP-ACG)
Respondents.
x-------------------------------------------------------x

PETITION
The Petitioner, through the undersigned counsel and unto this
honorable court, respectfully avers:

1. The Petitioner is of legal age and Chinese national. He is residing at

Block 12 Lot 9 East Ventura Street, Pacific Woods, Subdivision,
Carsadang Bago 2 Imus, Cavite, where he/she may be served with the
processes of this honorable court;
2. The Respondents are PNP-NCRPO with headquarters at 12 Paraiso,
Lower Bicutan, Taguig, 1632 Metro Manila; and PNP-ACG with
headquarters at Anti-Cybercrime Group Building Col. Lagman St.,
Bagong Lipunan Camp Crame, Quezon City, Metro Manila, Philippines
1100. They are likewise holding office at Hong Tai Building Complex –
Building C located at 1750 Alabang–Zapote Rd, Almanza Uno, Las
Piñas, Metro Manila where they may be served with the processes of
this honorable court.
3. The Petitioner in whose behalf this application is being made, is actually
restrained of his/her liberty by the Respondents-PNP-NCRPO and PNP-
ACG at Hong Tai Building Complex located at 1750 Alabang–Zapote
Rd, Almanza Uno, Las Piñas, Metro Manila;
4. On June 26 at 10:00 in the evening, Petitioner was taken into custody by
the said Respondents without a warrant of arrest and detained at Hong
Tai Building Complex without any criminal charges being filed against
them before the proper judicial authorities despite the lapse of required
period;
5. Moreover, Petitioner was taken by the Respondents not under any of the
circumstances where a warrantless arrest is allowed by the law or the
Rules of Court;
6. Such restraint of liberty of the Petitioner by the Respondents is therefore
without any legal authority;
7. The Petitioner through counsel has exhausted all efforts available at law
but to no avail, and that they have no other plain, speedy, and adequate
remedy to protect their personal rights and secure these personal
liberties except by this application for a Writ of Habeas Corpus.
PRAYER

WHEREFORE, Petitioner most respectfully prays that a Writ of

Habeas Corpus be issued by this Honorable Court, directed to any
members of officers of PNP-NCRPO and/or PNP-ACG, commanding
the Respondent to produce the body of XIAO YONGJIANG WITH
PASSPORT NO. PROC-EF0395087 before this Court at the time and
place therein specified, and to summon the Respondents then and there to
appear and to show cause of the detention of said Petitioner; and that after
due proceedings, the said Petitioner be restored of his/her liberty and
forthwith discharged from confinement.

20 July 2023, Parañaque City for Las Piñas City.

Republic of the Philippines )

Las Piñas City )SS
x--------------------------------------x

VERIFICATION AND CERTIFICATION

I, XIAO YONGJIANG WITH PASSPORT NO. PROC-

EF0395087, of legal age and resident of Block 12 Lot 9 East Ventura
Street, Pacific Woods, Subdivision, Carsadang Bago 2 Imus, Cavite, hereby
depose and state the following:
I am the Petitioner in the above stated case and that I caused the
preparation of the foregoing petition;
I 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;
That the petition is not filed to harass, cause unnecessary delay, or
needlessly increase the cost of litigation; The factual allegations therein
have evidentiary support or, will likewise have evidentiary support after
reasonable opportunity of discovery;
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;
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;
 If I should thereafter learn that a similar action or proceeding has been
filed or is pending in any court, tribunal, or agency, I undertake to report
that fact within five (5) days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have affixed my signature this July 20,

2023 at Las Piñas City.

XIAO YONGJIANG PASSPORT NO. PROC-EF0395087

SUBSCRIBED AND SWORN to before me in the date and place above-

mentioned, affiant exhibited to me his/her Passport representing him/her to be the
person who executed this verification and certification.

Doc. No. _________;

Page No. _________;
Book No. ________;
Series of 2023.