REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

REGION XI
DAVAO CITY, BRANCH 10

SLICK RICK,
Plaintiff,

---- versus ---- Spec. Proc. No. 11211

For: WRIT OF AMPARO and
HABEAS CORPUS with
prayers for Protection Order

JOHN WICK,
Defendant
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PETITION

The PETITIONER, through Counsel, and unto this Most Honorable

Court, respectfully avers:

1. That petitioner is a filipino and residing at 55 Super st., GSIS Heights,

Matina, Davao City and is the aggrieved party and victim in this
Petition and he can be served with processes of this Honorable Court at
her attorney-in-fact and her lawyer’s address at Unit 11 and 12, City
Triangle, CM Recto, Davao City;

2. Respondent JOHN WICK, a member of the Philippine Armed Forces

with a rank of major and is currently stationed at the 25th Infrantry
Division of Camp Bonifacio and who can be served with summons and
other court processes and matters at Camp Holiday, Torres st., Davao
City;

3. Certain persons named El Dorado, Guy Lumbardo and Slick Rick, were
abducted and kidnapped by about five (5) armed men with strong
evidence of being military personnel on January 10, 2020 at Marfori
Road, Davao City;

4. Petitioner and his companions were abducted and kidnapped without

any legal ground, authority, and basis for being believed by their
abductors and kidnappers to be members of the New People’s Army
(NPA) Sparrow Unit;
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 5. Petitioner underwent tactical interrogation and was tortured (attached
affidavit and medical certificate as Annexes “A” and “B”) heavily
causing trauma and depression and fear for his life;

6. The lives, liberty, and security of petitioner and his family have been
threatened by the abductors and kidnappers of petitioner and are in real
imminent danger and threat;

7. The petitioner was blindfolded when he and his companions were

transported, however, the distance of the travel and the sounds heard by
the petitioner in the place where they were brought as well as the
buildings described by the him are places inside Camp Bonifacio;

8. When petitioner and his companions were abducted, a certain person

named DOLPH LUNGREN and his group made investigations of their
disappearance and reported the matter to police authorities (attached
police report as Annex “C”);

9. The initial reports tallied with the same patterns of abduction and
kidnapping done by the military forces to commit the crime with
impunity and done brazenly only which can be done by people who are
authorities;

10.The police and military authorities and the office of the president have
not done anything to investigate their personnel in the commission of
this devious crime and if any investigation was shallow and pro-forma
without any intention of really solving the crime;

11.The petitioner has been declared by those who abducted as being in the
NPA Sparrow Unit and has been investigated to be a member of the
NPA group without the presence of counsel despite persistent demand
for one. The labeling and the listing as a member of the Sparrow Unit
is a violation of his privacy rights and these list and label must be
expunged from the records including all records taken during the said
interrogation.

12. That EL DORADO and GUY LUMBARDO are still in the custody of
RESPONDENT Major JOHN WICK without legal justification and
despite repeated demands for their release, he continually refuses to
comply with the demands.

PRAYER

WHEREFORE, it is mostly respectfully prayed unto this Honorable

Court that a WRIT OF AMPARO granting the issuance of Protection Order
in favor of PETITIONER SLICK RICK and his family against and from

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RESPONDENT JOHN WICK and to enjoin respondent from doing harm or
even approaching the said persons.

IN THE EVENT THAT THE RESPONDENT WOULD DENY

CUSTODY, it is mostly respectfully prayed unto this Most Honorable Court
to allow the inspection of the detention areas of the 10th Infantry Division at
Camp Holiday, Torres St., Davao City.

LIKEWISE, the records pertinent in any way to SLICK RICK in the

hands of the respondent be expunged and should forever be disabused and
should not be used anymore.

FINALLY, it is mostly respectfully prayed unto this Honorable Court

that a WRIT OF HABEAS CORPUS BE GRANTED ORDERING THE
RESPONDENT to immediately release the companions of the petitioner
namely: EL DORADO and GUY LOMBARDO.

RESPECTFULLY SUBMITTED.

DONE. Davao City, Philippines on February 6, 2020

SLICK RICK
Plaintiff

Assisted by:

ATTY. PAULO JOSE S. VILLARIN

Counsel of the Plaintiff
Roll of Attorneys No. 696969
PTR No. 69669, 4-24-20, Davao City
IBP No. 69669, 4-24-20, Davao City
MCLE Compliance No. VII-0220293; 4-19-19
Valid until April 14, 2022
Ecoland, Davao City

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REPUBLIC OF THE PHILIPPINES)
CITY OF DAVAO ) S.S.
x----------------------------------------------x

VERIFICATION AND CERITIFICATION

I, SLICK RICK, of legal age, Filipino citizen, and resident of 55 Super

st., GSIS Heights, Matina, Davao City, under oath, depose and state:

1. That I am the Petitioner in the above-mentioned case;

2. That I have caused the preparation of this Petition;

3. That I have read and understood its contents and affirm that they are
true and correct to my personal knowledge and based on authentic
records; and

4. That I hereby certify that there is no other case or special proceeding

commenced or pending before any court involving the same parties
and the same issue and that should we learn of such a case or special
proceeding, we shall notify the court within five (5) days from our
notice.

IN WITNESS WHEREOF, I have signed this instrument on the 6th

day of February 2020, in the City of Davao, Philippines.

SLICK RICK
Affiant

SUBSCRIBED AND SWORN TO before me this 6th day of February

2020 the affiant namely SLICK RICK exhibiting to me his Driver’s License
No. 102332 and issued on November 10, 2019 and issued at Davao City,
Philippines

Doc. No. __ ;
Page No. ___ ;
Book No. ___;
Series of ___ .

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