Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
BRANCH 3
Baguio City

DEMPSEY G. CODAMON,
Petitioner, SPEC. PROC. CASE No. 2759–R

For:
- versus -
CUSTODY of the MINOR
DIXIE KATE M. CODAMON
JANICE B. MANUEL, (HABEAS CORPUS)
Respondent.
x---------------------------------------------x

URGENT MOTION

COMES NOW, the Respondent, through the undersigned counsel,

and unto this Honorable Court, most respectfully states that:

1) Based on the recommendation of the court social worker, the

Respondent-movant is given the right to take the subject child
from the temporary custody of the Petitioner on weekends so as
to strengthen the bond between mother and child, which was
discussed during the last hearing on 12 October 2018;

2) Pursuant to the above, in the evening of 16 November 2018,

respondent-movant, accompanied by her spiritual adviser,
Bernadeth Labagan, went to the residence of Petitioner but was
turned away by the petitioner’s brother, one Jhun Lagdao, citing
that she cannot take said child, which was likewise reiterated by
the petitioner, claiming that he should also be allowed to have
custody of the parties’ other child, Dempsey M. Codamon, Jr.;

3) The behavior of the petitioner and his gang of thugs is

plainly in defiance of the Honorable Court’s Order, thus, should
be sanctioned accordingly;

4) In the meantime, it has become imperative that a court order

be issued directing the Honorable Court’s Sheriff or any
operative of the Philippine National Police to achieve the goal of
this Honorable Court, i.e. the establishment of a good
relationship of the child with both parents, as stated in its Order
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 dated 12 October 2018, on the 23rd of October 2018 and every
succeeding Friday, if necessary.

PRAYER

WHEREFORE, premises considered, it is so respectfully moved.

Other reliefs, just and equitable, are likewise prayed for.

This 19th day of November 2018, in the City of Baguio, Philippines.

A B S LAW OFFICES
Suite 305, Laperal Building
Session Road, Baguio City
(Tel. No. (074) 442-8243)

By:

JUAN ANTONIO REYES ALBERTO III

PTR No. 3418024/12.20.2017/Baguio City
IBP Life No. 01059/12.20.1996/Baguio City
MCLE V No. 0002889/07.03.2014
Roll No. 35781

NOTICE

The BRANCH CLERK of COURT

Regional Trial Court – Branch 3
Justice Hall, Baguio City

ATTY. GUILLERMO R. BANDONILL, Jr.

Counsel for the Petitioner
Room 307 Laperal Building
Session Road, Baguio City
2600 Philippines
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Greetings:

Please take notice that on 21 November 2018 at 8:30 a.m., or as

soon thereafter as counsel and the matter may be heard, the undersigned
will submit the foregoing Urgent Motion for the approval of the
Honorable Court.

JUAN ANTONIO REYES ALBERTO III

Copy furnished:

ATTY. GUILLERMO R. BANDONILL, Jr.

Counsel for the Petitioner
Room 307 Laperal Building
Session Road, Baguio City
2600 Philippines

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