Regional Trial Court: Petitioner

FORM_31
Republic of the Philippines

REGIONAL TRIAL COURT
Third Judicial Region
Branch IV
Angeles City
IRIS ANN D. CAMERO,

Petitioner,
SP. Proc. No. RR-4444
- versus -
FOR: Habeas Corpus of
Minor Sebastian Vincent D.
Camero
CARLOS ALLEN V. CAMERO,
Respondent.
x----------------------x
PETITION
PETITIONER Iris Ann D. Camero, by counsel, respectfully

states that:
1. Petitioner is of legal age and with residence at #111 St., Jude,

Brgy. Alfonso, Angeles City, Pampanga, Philippines. Petitioner
is the mother of Sebastian Vincent D. Camero, who was born
out of the valid marriage between petitioner and respondent
Carlos Allen V. Camero;
2. The marriage failed and petitioner has been living separately

from respondent since 2016. On April 1, 2020, respondent
asked her permission to take Sebastian Vincent D. Camero in
Enchanted Kingdom, promising that he would return their minor
child on April 2, 2020. However, respondent kept the minor
child incommunicado and out of petitioner’s reach;
3. Being below seven (7) years of age, custody of the minor is

naturally presumed to belong to petitioner, as their mother.
Consequently, respondent’s refusal to allow petitioner to regain
custody over the minor is unlawful and unjustified; and
4. Petitioner, through counsel, has exhausted all efforts available

at law, and that she has no other plain, speedy, and adequate
remedy to protect her personal rights except by her application
for a Writ of Habeas Corpus.
Page | 1
FORM_31
RELIEF
WHEREFORE, Petitioner respectfully prays that a writ of

habeas corpus issue directing respondent to make a return showing
his legal authority to detain the minor children, subject of this petition,
and thereafter, present the minor children personally before the Court
on a date and time it chooses.
Other relief just and equitable are likewise prayed for.
Respectfully submitted.
Angeles City, Philippines, 29 May 2020.
(Sgd.) ATTY. RAYMOND G. RONQUILLO

Counsel for Petitioner
RONQUILLO & ASSOCIATES LAW OFFICE
Rm. 404 RGR Bldg., McArthur Hi-way, Salapungan, Angeles City
IBP Lifetime No. 000000/Pampanga
PTR No. 0000000/January 02, 2020/Angeles City
Supreme Court Roll of Attorney’s No. 00000
MCLE Compliance No. V–0000000/October 01, 2019
VERIFICATION AND CERTIFICATION OF NON-FORUM

SHOPPING
I, Iris Ann D. Camero, Filipino, of legal age, after been duly

sworn, depose and state that:
1. I am the Petitioner in the foregoing Petition for Habeas

Corpus
2. I caused the preparation of the foregoing Petition which I
have read and understood.
3. I hereby affirm that all factual allegations contained in the
said Complaint are true and correct of my own personal
knowledge and belief, as well as true and correct basis of
authentic documents and records in my possession.
4. I further certify that I have not commenced any other action
involving the same issues before the Supreme Court, Court
of Appeals or any division thereof or any tribunal or agency;
and to the best of my knowledge no such action is pending
before the Supreme Court, Court, Court of Appeals or any
division thereof or any tribunal or agency.
Page | 2
FORM_31
In the event that any action involving the same should be made
known, I hereby bind myself to report the same within five (5) days
from knowledge thereof to this Honorable Court.
IN WITNESS WHEREOF, I hereunto set my hand this 29 th day

of May 2020 at Angeles City, Philippines.
(Sgd.) IRIS ANN D. CAMERO

Petitioner
SUBSCRIBED AND SWORN to before me, this 29th day of May

2020, in Angeles City, Philippines, by the following whom I have
identified through competent evidence of identity and who exhibited to
me the same as follows:
PERSONS COMPETENT EVIDENCE OF

IDENTITY
IRIS ANN D. CAMERO UMID No. CRN-0062-1245678-9

Date of Issue: N/A
Doc. No. 31; ATTY. RENEE MIRIELLE G. DELA CRUZ

Notary Public for Angeles City
Page No. 07; DELA CRUZ & ASSOCIATES LAW OFFICE
Book No. I; Rm. 209 PS Bldg., McArthur Hi-way, Salapungan,
Angeles City, Philippines
Series of 2020. Roll No. 00000, June 4, 2017
Commission Serial No. 0000-000
Valid until December 31, 2021
IBP Lifetime No. 000000/Pampanga
PTR No. 0000000/January 04, 2020/Angeles City
EXPLANATION
This certifies that personal service was not resorted to for the
reason that due to time, distance and manpower constraints, the
same is not practicable.
(Sgd.) ATTY. RAYMOND G. RONQUILLO
Copy Furnished:
Page | 3
FORM_31
CLERK OF COURT
Regional Trial Court
Branch IV, Angeles City
CARLOS ALLEN V. GO
Respondent
19-30 Yvette St. Essel Park
Subdivision, Brgy. Telabastgan,
Angeles City, Pampanga
Page | 4

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FORM_31

Republic of the Philippines

IRIS ANN D. CAMERO,

PETITIONER Iris Ann D. Camero, by counsel, respectfully

1. Petitioner is of legal age and with residence at #111 St., Jude,

2. The marriage failed and petitioner has been living separately

3. Being below seven (7) years of age, custody of the minor is

4. Petitioner, through counsel, has exhausted all efforts available

WHEREFORE, Petitioner respectfully prays that a writ of

Other relief just and equitable are likewise prayed for.

Angeles City, Philippines, 29 May 2020.

(Sgd.) ATTY. RAYMOND G. RONQUILLO

VERIFICATION AND CERTIFICATION OF NON-FORUM

I, Iris Ann D. Camero, Filipino, of legal age, after been duly

1. I am the Petitioner in the foregoing Petition for Habeas

IN WITNESS WHEREOF, I hereunto set my hand this 29 th day

(Sgd.) IRIS ANN D. CAMERO

SUBSCRIBED AND SWORN to before me, this 29th day of May

PERSONS COMPETENT EVIDENCE OF

IRIS ANN D. CAMERO UMID No. CRN-0062-1245678-9

Doc. No. 31; ATTY. RENEE MIRIELLE G. DELA CRUZ

(Sgd.) ATTY. RAYMOND G. RONQUILLO

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