Caption: Republic of The Philippines Regional Trial Court Second Judicial Region Branch 111 Cauayan City, Isabela
Caption: Republic of The Philippines Regional Trial Court Second Judicial Region Branch 111 Cauayan City, Isabela
Caption: Republic of The Philippines Regional Trial Court Second Judicial Region Branch 111 Cauayan City, Isabela
VICO SOTTO,
Respondent
X-------------------------X Title
PETITION
2. BODY
Petitioner, through the undersigned counsel, unto this Honorable
Court, respectfully states that:
3. The Petitioner and the Respondent are husband and wife. Copy of
their certificate of marriage is hereto attached and marked as Annex
“A”.
Allegations
Page 1/6
4. That during their cohabitation they begot a child named ISKO
BELMONTE SOTTO who was born on March 15, 2014 at Ester Garcia
General Hospital, San Fermin, Cauayan City, Isabela. Copy of the
Certificate of Live Birth is hereto attached and marked as Annex “B”.
5. That since birth, the child Isko B. Sotto resided with the Petitioner at
San. Fermin, Cauayan City, Isabela and he is currently enrolled as
nursery student at San Fermin Day Care Center where he has made
so many friends.
6. That Petitioner and Respondent separated on May 2015 due to the fact
that Respondent was maintaining a mistress at Minante 1, Cauayan
City, Isabela and that said mistress also begot a child on April 2015.
Since May 2015 the Respondent left their conjugal dwelling and lived
with his mistress at Minante 1, Cauayan City, Isabela.
7. That on April 15, 2020 at around 2:00 o;clock in the afternoon, the
Respondent went to the residence of the Petitioner and asked to
borrow the minor child Isko allegedly to treat him at Jollibee. The
Petitioner gave in and allowed Respondent to bring the child to
Jollibee with the Respondent. That at around 5:00 o’clock in the
afternoon, the Petitioner was calling the Respondent however his
phone was turned off. At around 7:00 o;clock in the evening and
receiving no word as to the whereabouts of her son, the Petitioner
went to Minante 1, Cauayan city, Isabela to look for the Respondent
and there she saw the minor child Isko inside the residence of
Respondent and his paramour/mistress. The Petitioner was further
shocked as she saw his son crying and when Isko saw her, he
immediately went to her and hugged her and begged to be brought
home at San Fermin as he claims that he was being introduced to
another child who is allegedly his sibling.
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9. That when Petitioner tried to leave with Isko, she was prevented by
the Respondent claiming that he also has the right of custody as he
is also the father. He then locked the door of the house and prevented
Isko to come out despite his crying and begging to be with
Petitioner.
10. Despite her pleas, the Respondent refused to open the door and allow
Petitioner to comfort her son.
13. That under the law a minor child under seven (7) years old should
remain in the custody of the mother.
14. That any issue of custody can be settled after the minor child is
returned to the custody of the mother.
Relief
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the hearing and to show cause the reason for the deprivation of liberty of the
minor child.
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REPUBLIC OF THE PHILIPPINES) Scilicet
PROVINCE OF ISABELA )
CITY OF CAUAYAN )
X---------------------------------------X TITLE
2. That I caused the preparation and filing of this petition and have
read and know the contents thereof, and that the allegations therein
are true and correct of my own knowledge;
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Issued by LTO
Cauayan
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Republic of the Philippines
REGIONAL TRIAL COURT
1.CAPTION
SECOND JUDICIAL REGION
Cauayan City, Isabela
Branch 111
KOKO PIMENTEL
Accused
x———————————x Title
2. Body
TIMELINESS OF THE MOTION
(a) That April 15, 2020 the Honorable Court rendered a Decision the
dispositive portion of which reads as follows: Decision of the court
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the indeterminate penalty of ten (10) years of prision mayor as
minimum to sixteen (16) years of reclusion temporal as maximum.
SO ORDERED.”
2. That the accused has fifteen (days) or until April 30, 2020 to file a
Motion for Reconsideration or New Trial hence this Motion is
timely filed.
4. That during the reception of evidence for the defense set on March
3, 10, 15 and April 2, 2020, the accused is suppose to be brought to
Grounds
court to testify. However the personnel of BJMP failed to bring the
accused to court.
5. There are two (2) reasons why the accused cannot be brought to
court. First is that the accused is suffering from chicken pox which
is highly contagious disease reason for which the BJMP Doctor
ordered that the accused remain in isolation. Second is that the
personnel of BJMP musty have confused the accused to another
inmate named Kiko Pangilinan who was the one brought to the
court.
6. That due to the failure of the accused to testify the Honorable Court
declared the accused to have waived his right to be heard and then
submitted the case for decision.
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7. That the accused did not waive his right to be heard, he was merely
prevented by his jailers to attend the hearing hence the accused
cannot be blamed.
8. That it is imperative that the accused be allowed to testify so that he
can establish his defense and prove his innocence of the crime
charged.
Attorney’s Box
Copy furnished
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Request for notice of hearing
TO THE CLERK OF COURT
RTC BRANCH 111
Please note that the undersigned counsel will ask the Honorable Court to
calendar the hearing of the instant Motion on May 1, 2020 at 9:00 o;clock in
the morning where counsel may be heard.
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1.CAPTION
Republic of the Philippines
SECOND JUDICIAL REGION
Municipal Trial Court in Cities
Cauayan City, Isabela
Name of the court
Docket number
Plaintiff
Parties
For; “Usurpation of Authority”
- versus –
HARRY S. ROQUE
Accused Title
x-----------------------------x
INFORMATION
2. Body
The undersigned City Prosecutor accuses, HARRY S. ROQUE of Purok 1,
San Fermin, Cauayan City, Isabela of the crime of Usurpation of Authority
defined and penalized under Article 177 of the Revised Penal Code committed
as follows; Allegations
That on or about the 20th day April 2020, in Barangay San Fermin,
Cauayan City, Isabela and within the jurisdiction of this Honorable
Court the above named accused did then and there willfully, unlawfully,
and feloniously, falsely represented himself as a police officer at the
check point at San Fermin, Cauayan City, Isabela by wearing a PNP
Uniform and presenting a fake PNP Identification card and introducing
himself as Major Harry Roque assigned as Provincial Intelligence Officer
and asked that he be exempted from securing a quarantine pass when in
truth and in fact he is no way connected to the PNP to the damage and
prejudice of the PNP Institution.
CONTRARY TO LAW.
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DATE
Cauayan City, Isabela April 21, 2020.
RODRIGO R. DUTERTE
Signature of the city City Prosecutor
prosecutor MCLE No. VI-1234567
Valid until April 2023
CERTIFICATION CERTIFICATION
RODRIGO R. DUTERTE
City Prosecutor
MCLE No. VI-1234567
Valid until April 2023
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