REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 1
Manila

JUAN DELA CRUZ,

Plaintiff,
CA-G.R. SCA No. 12345
For: Certiorari under
-versus- Rule 65 of the Rules of
court

PEDRO ALEJANDRO, as
Presiding Judge, Branch 4, Regional Trial Court
Manila, and MARIA REYES – DELA CRUZ,
Respondents.
x-----------------------------------------x

PETITION FOR CERTIORARI

Petitioner JUAN DELA CRUZ (hereinafter “Dela Cruz”); by counsel respectfully states:

I.
NATURE OF THE PETITION
This is a Petition for Certiorari under Rule 65 of the ROC, respectively, seeking the
reversal of the Decision rendered on 1 February 2016, denying the Petition for Legal Separation
on the ground of compelling legal arguments.

II.
TIMELINESS OF THE PETITION

1. On 3 February 2016, Dela Cruz received the Notice od Decision/Resolution Entered and
the Decision dated 1 February 2016 of public respondent Alejandro.
2. There is no appeal, or any plain and speedy remedy in the ordinary course of law other
than the instant petition.
3. Under the foregoing circumstances, petitioner Dela Cruz is constrained to file this
Petition for Certiorari for the consideration of this Honorable Court.
4. From the foregoing, Dela Cruz has sixty (60) days from 1 February 2016 until 1 April
2016, within which to file the instant Petition for Certiorari.

III.
THE PARTIES

5. Petitioner Dela Cruz, of legal age, Filipino, with residence at 1 Recto Ave., Manila. He is
the spouse of respondent Maria Reyes – Dela Cruz.
6. Dela Cruz may be served with notices, orders, resolutions and other processes of this
Honorable Court through the undersigned counsel at the address indicated below.
7. Public Respondent Honorable Judge Pedro Alejandro is the judge that issued the
assailed Decision.
8. Private respondent Maria Reyes – Dela Cruz is the spouse of Petitioner. She may be
served with notices, orders, resolutions and other processes of this Honorable Court at 1
Recto Ave., Manila.
 IV.
STATEMENT OF THE FACTS

V.
STATEMENT OF ISSUED

VI
GROUNDS FOR THE ALLOWANCE OF THE PETITION

VIII.
DISCUSSION

WHEREFORE, premises considered, Petitioner respectfully prays that this

Honorable Court annul, reverse and set aside the Decision of the Regional Trial Court
of Manila, Branch 4, denying the petition for legal separation.

Other reliefs as may be just and equitable are likewise prayed for.

City of Manila, Philippines, March 30, 2016.

ATTY. JUANICO FRANCISCCO

Counsel for Defendant
Unit 1, X Building, Recto, Manila
IBP No. 123456; 01/10/10 – Manila
PTR No. 1234567; 01/10/10 – Manila
Roll No. 12345; 5/05/05
MCLE No. I – 001234; 9/09/09
MCLE No. II – 115678; 9/09/09

Copy furnished:
Name and Address of Counsel of the Other Parties

VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING

PROOF OF SERVICE