REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 1
Manila

IN THE MATTER OF THE PETITION

FOR CHANGE NAME OF BOY BASTOS
TO ANTHONY SANTOS

SP. Proc. No. 000001

BOY BASTOS
Petitioner,
x-----------------------------------------x

PETITION

Petitioner, by the undersigned counsel, respectfully avers that:

1. The petitioner is of age, single and a resident of 22 Recto Ave., Manila;

2. He has been a bonafide resident of the City of Manila since the year 1984, or of at least
three (3) years prior to the date of the filing of his petition;
3. The petitioner’s present name is Boy Bastos
4. He was born on July 15, 1984 and his father’s name is, Joaquin Bastos while his
mother’s name is Anita Santos. His birth certificate showed that the name given was Boy
Bastos, true copy of which is attached hereto as Annex “A”. his school records until he
finished college carried the name of Boy Bastos.
5. Petitioner has no alias name;
6. The family name, which carries, “Bastos”, means in English, “perverted, uneducated or
ill-mannered” which evoked derisive laughter among his schoolmates and neighbors and
has caused him embarrassment in his school and social dealings.
7. The petitioner desires to change his name from Boy Bastos to Anthony Santos, which is
a surname of his mother, to avoid derisive laughter among his schoolmates as he now
intends to find work after college and settle in the future. He did not want that his
children would suffer the same derisive remarks and embarrassment, as what petitioner
has suffered for long.

WHEREFORE, it is respectfully prayed that, after due notice and publication in accordance
with the ROC, and hearing this Honorable Court adjudge that the petitioner’s name of Boy
Bastos be changed to Anthony Santos.

COMES NOW, petitioner, thru the undersigned counsel, respectfully avers that:
 PARTIES

1. Petitioner Juan dela Cruz, is a Filipino, of legal age, and residing at 8 Recto Ave.,
Manila. He may be served with notices from this Honorable Court through his
undersigned counsel. Petitioner is the brother of the aggrieved victim, Mario dela Cruz.
2. Respondent Gen. Manny Nindak is the head of the Armed Forces of the Philippines
(AFP). He may be served orders and processes at AFP-GHQ, Camp Aguinaldo, Cubao,
Quezon City.

MATERIAL ALLEGATIONS:

1. The victim is a private individual residing at 8 Recto Ave., Manila and is a bonafide
student of X School, Mendiola, Manila.
2. The victim regularly travels from his place of residence to his school by walking.
3. The victim was last seen on 10 January 2015 in a mass protest in Mendiola, Manila.
4. On said date, the victim was seen accompanied by, and possibly even in the custody of,
respondent’s subordinates.
5. During the time of the victim’s disappearance, the respondent’s subordinated were
known to be conducting operations/activities in the vicinity where the victim was last see,
near Recto Ave., where the victim would have passed on his way home.
6. Since then, no communication to any family member, friend or schoolmates has been
made by the victim.
7. Since the victim’s disappearance, his relatives and friends have tried to personally locate
the victim through inquiries at his usual place of destination.
8. Failing to find the victim, the petitioner, along with other concerned citizens immediately
sought the help of local authorities.
Copies of the reports made to local authorities such as barangay blotter, police blotter,
letters, and complaints filed are hereto attached and made integral part hereof as
Annexes “A, B, and C”, respectively.
9. None of these authorities were able to produce the person of the victim.
10. However, in the course of these investigations, the following reports were mad:
Copies of the findings of the investigations conducted by local authorities are hereto
attached and made integral part hereof as Annexes “D, E, and F”.
11. Given the circumstances surrounding the victim’s disappearance, there can be no basis
for a presumption that said disappearance is with the victim’s consent.
12. Petitioner now comes to this Honorable Court to seek relief for the victim whose exact
whereabouts remain unknown.
13. Also considering the fact that the victim is a private individual or a civilian and that he
has failed to communicate with any of his relatives until this time, victim’s remaining in
custody under respondent’s authority would have to be against his will and in violation of
his right to liberty and security.

RELIEFS
 Petitioner respectfully moves for the issuance of the protective reliefs available under the
Rule on the Writ of Amparo, specifically:

a. An INSPECTION ORDER directed to Col. Pedro Santos for the inspection of Y Cell, in
the AFP Headquarters, Camp Aguinaldo, Cubao, Quezon City where the victim was
supposedly held in custody prior to the filing of this petition; and
b. A PRODUCTION ORDER directed to Col. Angelo Angeles for the production of the
victim’s laptop, cellphone, wallet, and other personal effects, which were in his
possession at the time of his disappearance.

In support of the motion for the issuance of an Inspection Order and Production Order,
petitioner respectfully adopts the affidavits of the witnesses, which are hereto attached as
Annexes “G, H and I”.

WHEREFORE, petitioner prays that this Honorable Court:

A. Immediately after the receipt of this petition:

1. ISSUE the writ of amparo against the respondent;
2. DECLARE VOID all documents signed by the victim since the time of his
disappearance unless proof be submitted that there has been compliance with all the
Constitutional rights of the victim, such as but not limited to the rights of a person
under custodial investigation;
3. REQUIRE respondent to disclose all medical examinations conducted on the victim
and produce reports of all said medical examinations;
4. REQUIRE respondent to produce all information he or his office holds pertaining to
the victim, the victim’s home, the victim’s family, and the victim’s correspondence;
5. REQUIRE respondent to explain the purposes for which such information was used;
6. ISSUE a Temporary Protection Order in favor of petitioner and his witnesses by
directing or accrediting the Department of Justice to ensure their protection;

B. Upon notice and hearing:

1. ISSUE an Inspection Order over the property which may contain additional
information or evidence regarding the enforced disappearance of the victim;
2. ISSUE a Production Order to persons who may be in possession or custody of other
evidence in this case; and
3. ORDER respondent to IMMEDIATELY release the victim to the custody of petitioner.

Other reliefs just and equitable under the premises are likewise prayed for.

City of Manila, Philippines, March 2, 2015.

 ATTY. JUANICO FRANCISCCO
Counsel for Petitioner
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

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