Republic of the Philippines

6th Judicial Region

Regional Trial Court
Branch 17
Roxas City
IN THE MATTER OF
THE PETITION
FOR THE
WRIT OF AMPARO
IN FAVOR
OF
JUAN DELA CRUZ,
SP. PROC. NO. _________
FOR: Writ of Amparo
JUAN DELA CRUZ,
Petitioner,
- versus
GEN. JOVITO PALPARAN,
X - - - - - - - - - - - - - - - -X

PETITIONERS thru counsel, unto this Honorable Court respectfully

avers that:
1. Petitioner is a Filipino citizen, of age and resident of Rizal Street, Roxas
City;
2. Petitioner is the mother of JUAN DELA CRUZ, 25 years old and residing
in the same address, in whose benefit this application is made;
3. Respondent GEN. JOVITO PALPARAN is the commanding general of the
Armed Forces of the Philippines, and who can be served with summons
and other court processes at Camp Peralta, Jamindan, Capiz;
4. Juan dela Cruz with two other companions Juanito Aquino and John
Travolta were abducted and kidnapped by about 15 armed men with
strong evidence of being military personnel on the early afternoon of
September 15, 2014 at Brgy. Baybay, Roxas City and were forcibly
brought to a place which is strongly believed to be Camp Peralta;

5. Petitioner and his companions were abducted without any legal

ground, authority and basis for being believed by their abductors and
kidnappers to be members of the CPP - New Peoples Army;
6. When Juan Dela Cruz was abducted, petitioner herein and a group of
concerned citizens known as KARAPATAN reported the matter to police
authorities;
7. The police and the military authorities have not done anything to
investigate their personnel in the commission of this dastardly crime
and if any investigation was made, the investigation was shallow and
pro-forma without any intention of really solving the crime;
8. That petitioners herein have exhausted all efforts legally available and
that there is no other plain, speedy, and adequate remedy to protect
the rights of the victims except by this application for a Writ of
Amparo;

PRAYER
WHEREFORE, it is respectfully prayed, that:
1. A writ of Amparo be immediately issued;
2. An inspection Order be issued ordering the respondent to permit entry
on the camp where the aggrieved party is suspected to be held, for
purposes of inspection.
3. Other reliefs just and equitable are likewise prayed for.

PAUL IVAN R. BATICADOS

PTR # 123456,01/07/14
LIFETIME MEMBER NO. 01032
Bilbao Street, Roxas City
Roll # 53743
MCLE
Compliance#
1018,
03/12/14

Republic of the Philippines)

City of Roxas
)S.S.
VERIFICATION AND CERTIFICATION
I, JUANA DELA CRUZ, of legal age, Filipino and a resident of Rizal
Street, Roxas City, after having been sworn to in accordance with law do
hereby depose and state: That she is the mother of the abducted victim
JUAN DELA CRUZ; she has caused the preparation of the above petition and
has read and knows the same; the Allegations therein are true to her
personal knowledge; she has not filed or commenced any action or
proceedings involving the same issues nor is there any action nor
proceedings before the Supreme Court, Court of Appeals, or in any tribunal
or agency with the same issues and parties and in the event that petitioner
would know that there is an action or proceeding involving the same issues
and parties, she undertakes to notify this Honorable Court of the pendency
of the said action within 5 days from knowledge thereof.
JUANA C. DELA CRUZ
SUBSCRIBED AND SWORN TO before me this 22nd day of September
2014 after petitioner exhibited to me her Voters ID No. 987653.

Notary Public