PETITION FOR CHILD CUSTODY

PETITIONER, by counsel and to this Honorable Court, respectfully

alleges:

1. Petitioner is of legal age and is a resident of ______, Lipa City, while

respondent, also of legal age, is residing at _______, where he may be
served with summons and other legal processes.

2. Petitioner and respondent were spouses and had one child, aged 4,
whose name is Jane Marie Marasigan.

3. Sometime on or about __________, petitioners husband got their child,

without the knowledge, nor consent of petitioner, and took her to where
respondent is staying and since then, he has refused and continues to
refuse to part with the child and to give to petitioner the physical custody
and care of said child, in violation petitioners right as a mother over her
minor chold, Jane Marie Marasigan and of the law which provides that no
child under seven years of age shall be separated from the mother, and
there is no compelling reason to rule otherwise.

4. Petitioner avers that she has the right of custody over the minor child; the
rightful custody of the child is being withheld from petitioner by
respondent; and it is to the best interest of the minor to be in the custody
of petitioner and not that of the respondent.

WHEREFORE, petitioner prays for judgment:

Awarding the physical custody and care of the child Jane Marie Marasigan
to petitioner;
a) Ordering respondent to give the minor child to the care and custody of
petitioner.
b) Petitioner further prays for such other reliefs as may be just and
equitable in the premises.

(Venue, date, signature)