Republic of the Philippines

SUPREME COURT OF THE PHILIPPINES

THIRD JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 42
Angeles City

IN RE: IN THE MATTER OF ADOPTION OF

MINOR GUMMYBEAR KARLOS AND
CHANGE OF NAME TO GUMMYBEAR
KARLOS EDUARDO SPECIAL
PROCEEDING NO.
R-2977

SPS.  MAKKI EDUARDO

and BITINA KARLOS
EDUARDO,
Petitioners.
x-------------------------------------------------------------- x

THE HONORABLE SOLICITOR GENERAL

Office of the Solicitor General
134 Amorsolo St., Legaspi Village,
Makati City

YOUR HONOR:

We are respectfully furnishing your Honor’s Honorable Office of a copy

of the Petition filed by Spouses Makki Eduardo and Bitina Karlos Eduardo,
petitioners/plaintiffs in the above entitled petition: In re: IN THE MATTER OF
ADOPTION OF MINOR GUMMYBEAR KARLOS AND CHANGE OF NAME TO
GUMMYBEAR KARLOS EDUARDO.

The aforesaid case will be scheduled for hearing upon receipt of your
Honor’s Entry of Appearance as Counsel for the Republic of the Philippines in
the above-captioned case and a written Authority deputizing the Office of the
Provincial Prosecutor to represent/assist your Honor’s good Office.

Please acknowledge receipt hereof.

Angeles City, 25 October 2020.

Gretchen Molina
GRETCHEN MOLINA
Branch Clerk of Court

Copy Furnished:

ATTY. APRIL ELENOR C. JUCO Mr. MAKKI D. EDUARDO and

Office of the City Prosecutor Mrs. BITINA KARLOS-EDUARDO
Hall of Justice Building, No. 16 Rodeo Drive, Marquee
Pulung Maragul, Angeles City, Place Subd. E1, Angeles
Pampanga City, Pampanga
 Republic of the Philippines
REGIONAL TRIAL COURT
THIRD JUDICIAL REGION
BRANCH 42
Angeles City

IN RE: IN THE MATTER OF

ADOPTION OF MINOR GUMMYBEAR
KARLOS AND CHANGE OF NAME TO SPECIAL
GUMMYBEAR KARLOS EDUARDO PROCEEDING 
NO.  R-2977

SPS.  MAKKI
EDUARDO and
BITINA KARLOS
EDUARDO,
Petitioners.

PETITION
COMES, NOW, THE PETITIONERS, thru their counsel, and
unto this Honorable Court, most respectfully allege the following,
to wit:

1. That petitioners are both of legal age, Filipino citizens,

married to each other, and residents of No. 16 Rodeo Drive,
Marquee Place Subdivision, E1, Angeles City, Pampanga,
where they may be served with the processes of this Honorable
Court;

2. That the petitioners were married on February 18, 2018 at

Angeles City, this fact is evidenced by their “Certificate of
Marriage”, a copy of which is attached herein as Annex
“A”;

3. That they desire to adopt the minor illegitimate child of

petitioner Bitina Karlos named GUMMYBEAR KARLOS, male,
three years of age, Filipino, and likewise residing at No. 16
Rodeo Drive, Marquee Place Subdivision, E1, Angeles City,
Pampanga;

4. That herein subject minor, was born at Angeles University

Foundation Medical Center on April 06, 2016 to BITINA
KARLOS, which proof of birth was duly registered in the
Register of Births of the Office of the Civil Registrar of

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 Angeles City, for which a “Certificate of Live Birth” was
issued. A machine copy of it is herewith attached as Annex
“B”. Further, the proof of birth of the subject minor was
also shown in a Certificate of Baptism issued by Holy Rosary
Parish Church. A machine copy of it is also herewith
attached as Annex “B-1”.

5. That the biological father of the subject minor, Rambo G.

Nuńeza, signify his written consent, freely, willingly and
voluntarily for the adoption of his son. Said biological father
of the minor child has no stable means of livelihood with
which to support his child’s basic, as well as essential needs.
His circumstances being so, and for the best interest of the
minor child, he had left her child under the care of the
petitioner and had consented for his child to be adopted by
the herein petitioners. Copy of his “Affidavit of Consent” is
hereto attached as Annex “C”;

6. That the subject minor has no real properties except for

some personal effects;

7. That the subject minor is physically fit to be adopted by the

petitioners. This fact is evidenced by the Medical
Certificate”, a copy of which is attached herein as Annex
“D”;

8. That the subject minor possesses all the qualifications and

none of the disqualifications for him to be adopted by the
herein petitioners;

9. That the herein petitioners possess all the qualifications and

none of the disqualifications to adopt the subject minor;

10. That the herein petitioners are in possession of full civil

capacity and legal rights to adopt the subject minor;

11. That the petitioners have not been convicted of any crime
involving moral turpitude. This fact is evidenced by the “NBI
Clearances” issued by National Bureau of Investigation
which are attached herein as Annexes “E” and “F”,
respectively;

12. That the herein petitioners are physically, mentally,

psychologically, emotionally qualified to adopt the said
minor, this fact is evidenced by the “Medical Certificates”
issued to the petitioners, copies of which are attached herein
as Annexes “G”, and “H” respectively;

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 13. That the herein petitioners are financially qualified to
adopt the said minor, this fact is evidenced by “Bank
Certificates” issued to the petitioners, copies of which are
attached herein as Annexes “I” “J” and “K” respectively;

14. This petition will serve the best interest and well-being of
the subject minor.

DOCUMENTARY AND OBJECT EVIDENCE IN SUPPORT

OF THE PETITION

1. Petitioners will present the following documentary and object

evidence during the supervised trial hearing to support the
material allegations in this Petition namely:

- Exhibit “A” is the petitioners’ Marriage Certificate to

prove that they were married on February 18, 2018;

- Exhibit “B” is the Certificate of Live Birth of adoptee

GummyBear Karlos to show that he was born on April 06,
2016;

- Exhibit “B-1” is the Baptismal Certificate of adoptee

GummyBear Karlos to show that adoptee GummyBear
Karlos was born on April 06, 2016;

- Exhibit “C” is the Affidavit of Consent of one Rambo G.

Nuńeza to prove his consent to the adoption of his son,
the herein adoptee GummyBear Karlos;

- Exhibit “D” is the Medical Certificate of adoptee

GummyBear Karlos to show that he is physically fit to be
adopted;

- Exhibit “E” is the NBI Clearance issued to petitioner

Bitina Karlos-Eduardo, to show and prove that she was
not convicted of any crime involving moral turpitude;

- Exhibit “F” is the NBI Clearance issued to petitioner

Makki Eduardo, to show and prove that he was not
convicted of any crime involving moral turpitude;

- Exhibit “G” is the Medical Certificate issued to petitioner

Bitina Karlos-Eduardo, to show and prove that petitioner

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 is physically, mentally, psychologically, emotionally
qualified to adopt the said minor;

- Exhibit “H” is the Medical Certificate issued to petitioner

Makki Eduardo, to show and prove that petitioner is
physically, mentally, psychologically, emotionally qualified
to adopt the said minor;

- Exhibit “I” is the Bank Certificates issued to petitioner

Bitina Karlos-Eduardo, to show and prove that she is
financially qualified to adopt the said minor;

- Exhibit “J” and “K” are the Bank Certificates issued to

petitioner Makki Eduardo, to show and prove that he is
financially qualified to adopt the said minor;

- Exhibit “L” is the Joint Affidavit of Petitioners Bitina and

Makki Eduardo, to form part and reinforce their petition.

WITNESSES IN SUPPORT OF THE PETITION

In addition to the pieces of documentary evidence mentioned and

attached to this Petition, petitioner intends to present the Tiffany
Lucman, the Regional Social Worker herein, to testify on the
Child Report and Home Study Report herein executed.

Petitioners respectfully reserve the right to present additional

witnesses, as may be necessary, during the trial of this case, or
during other incidents requiring the presentation of a witness.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed

of this Honorable Court to grant this petition of Spouses Makki
and Bitina Carlos-Eduardo, for the adoption of GummyBear Karlos
and for the change of the child’s name to GummyBear Karlos-
Eduardo.

Such other reliefs which the Honorable Court may deem just
and equitable under the premises are likewise prayed for.

RESPECTFULLY SUBMITTED.

Angeles City, Philippines, October 02, 2020.

4
 ACJuco
Atty. April Elenor C. Juco
Office of the City Prosecutor
Hall of Justice Building,
Pulung Maragul, Angeles City,
Pampanga

5
Republic of the Philippines )
Angeles City ) S.S.

CERTIFICATION

I, ATTY. APRIL ELENOR C. JUCO, counsel for Petitioner of

legal age, Filipino citizen, and with office address at Unit 209,
MCFS Bldg, Mc Arthur Hi-way, Brgy. Pandan, Angeles City,
hereby freely depose and say:

1. That I have read the allegations contained in this pleading

and document; and

2. That to the best of my knowledge, information and belief,

formed after an inquiry reasonable under the circumstances:

a. It is not being presented for any improper purpose,

such as to harass, cause unnecessary delay, or
needlessly increase the cost of litigation;

b. The claims, defenses, and other legal contentions are

warranted by existing law or jurisprudence, or by a
non-frivolous argument for extending, modifying, or
reversing existing jurisprudence;

c. The factual contentions have evidentiary support so

identified will likely have evidentiary support after
availment of the modes of discovery under these Rules;
and

d. The denials of factual contentions are warranted on the

evidence so identified are reasonably based on belief or
a lack of information.

IN WITNESS WHEREOF, I have hereunto affixed my

signature this 2nd day of October, 2020 in Angeles City.

ACJuco
ATTY. APRIL ELENOR C. JUCO
Office of the City Prosecutor
Hall of Justice Building,
Pulung Maragul, Angeles City,
Pampanga

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Republic of the Philippines )
Angeles City ) S.S.

VERIFICATION AND CERTIFICTAION AGAINST FORUM

SHOPPING

We, PETITIONERS MAKKI EDUARDO and BITINA

KARLOS-EDUARDO, of legal age, Filipino citizen, and a
resident of No. 16 Rodeo Drive, Marquee Place Subdivision,
E1, Angeles City, Pampanga, on oath, say:

3. That we have read the allegations contained therein which

are true and correct based on our personal knowledge and
authentic records;

4. That the complaint is not filed to harass, cause unnecessary

delay, or needlessly increase the cost of litigation;

5. That the factual allegations therein have evidentiary support;

6. That we hereby certify that we have not commenced any

other action or proceeding involving the same issues in any
court, tribunal or quasi-judicial agency and, to the best of our
knowledge, no such other action or claim is pending therein;
and

7. That if we should thereafter learn that a similar action or

claim has been filed or is pending, we hereby undertake to
report such fact within five (5) calendar days therefrom to
this Honorable Court.

IN WITNESS WHEREOF, I have hereunto affixed my

signature this 10th day of February, 2021 in Angeles City.

Makki Eduardo
Makki D. Eduardo
Bitina Karlos-Eduardo
Bitina Karlos- Eduardo
Affiant Affiant

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 SUBSCRIBED AND SWORN to before me this 02 day of
October, 2020 in Angeles City, affiant exhibiting to me her
Philippine Passport No. BAR88885 issued by DFA Pampanga on
July 20, 2020 at DFA Robinsons Starmills Pampanga.

Kim Matic
ATTY. KIM MATIC
NOTARY PUBLIC
Until December 31, 2021
PTR No. 567891, Angeles City
IBP LIFE No. 010203 / ROLL No. 61287
Angeles City

Doc. No. 476;

Page No. 96;
Book No. 75;
Series of 2021.

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 COPY FURNISHED BY REGISTERED MAIL WITH
EXPLANATION THUS:

Because of the impracticability of messengerial service and

the distance between the offices of the parties and their counsel,
the original is filed and copies are furnished by registered mail
pursuant to Sec. 7, Rule 13 of the Revised Rules of Court.

ACJuco
ATTY. APRIL ELENOR C. JUCO
Office of the City Prosecutor
Hall of Justice Building,
Pulung Maragul, Angeles City,
Pampanga

Copy Furnished:

THE HONORABLE SOLICITOR GENERAL

Office of the Solicitor General
134 Amorsolo St., Legaspi Village,
Makati City

Mr. MAKKI D. EDUARDO and

Mrs. BITINA KARLOS-EDUARDO
16 Rodeo Drive, Marquee Place Subd,
Angeles City, Pampanga