Republic of the Philippines

Third Sharia District Court

Zamboanga City

Ms. Shusuka S. Ryuzaki, plaintif

Civil Case No. 1
Accompanied by her Attorney in fact,
Custody
Atty. Damulag D. Yoyoji

for:

-versusMr. Nobita S. Ryuzaki

x-----------------------------------------x
COMPLAINT

COMES NOW, the plaintif together with the undersigned

counsel to this most honorable court, MOST RESPECTFULLY STATES
THAT;
1. The Plaintiff is of legal age, divorced and a resident of Guiwan Barangay,
Zamboanga City.
2. The Defendant is likewise of legal age, married and temporary residing at
Talon-Talon, Zamboanga City.
3. The plaintiff was married but is now separated to the defendant through a
writ of divorce issued on April 30, 2015 by the court of proper jurisdiction.
4. The plaintiff and the defendant, upon the issuance of the writ if divorce,
agreed that the custody of their 5 year old daughter shall be with the mother
subject to the visitation of the father at his and the childs most convenient
time.
5. The defendant, however, did not honor such agreement when he came home
on May 29, 2015 from a vacation in Baguio City and happened to have
visited the child on the same day in Guiwan Elementary School, Guiwan
Barangay and subsequently invited the child for a lunch at the nearest
Jollibee Fast Food in Yubenco Mall Putik and unfortunately did not return to
the yayas fright.
6. The plaintiff on the night of the same day and the following days went to the
residence of the defendants parents where the defendant stays to ask and
beg for the return of the child but to no avail.
7. That until now, after several pleadings made by the plaintiff to the defendant
whether in person or through other medium of communication such as text
messages, phone calls, facebook chats, the defendant is likely to be deaf to
the lamentations of the plaintiff as a mother longing to the presence of her
only daughter and seemed to forget the terms and conditions they agreed
upon with regard to the custody of the child.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this
Honorable Court that judgement be rendered in favor of the plaintiff.
Judgements prayed are the following:
a.
The defendant shall give to the plaintiff the custody of the child in the
person of Doraemon Ryuzaki.
b.
The defendant shall be ordered to pay P 80, 000 for the Attorneys Fees.
Such other reliefs and remedies under the premises are likewise
prayed for.
Zamboanga City, Philippines, this 4th day of June 2015.

Atty. Damulag D. Yoyoji

Counsel for the Plaintif
PTR No. 18909595:1-04-07:B.C.
IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97: Manila
Rm. 4 2/F Zamboanga Boating Center
Zamboanga City

VERIFICATION AND CERTIFICATION

I, Mr. Shusuka Ryuzaki, of Legal age, divorced, Filipino Citizen and a resident
of Guiwan Zamboanga City, after being sworn according to law, hereby
depose and state that;
1.
2.

I am the Complainant in this proceeding.

I have read and understood the filed complaint and allegations therein.
Shusuka S. Ryuzaki
Complainant
In witness thereof, I, Atty. Damulag D. Yoyiji, counsel of the plaintiff, have
hereunto set my hand this 4th day of June at Zamboanga City.

Atty. Damulag Yoyoji

Counsel for the Plaintif
PTR No. 18909595:1-04-07:B.C.
IBP No, 693095:1-04-07:B.C.
Roll No. 42481:5-10-97: Manila
Rm. 4 2/F Zamboanga Boating Center
Zamboanga City