Republic of the Philippines

COURT OF APPEALS
Cordillera Administrative Region

W Bangco-og
Petitioner

vs. Special Proceeding No. 77777

In Re: Petition for Habeas Corpus of
the Minor F Bangco-og

X Britton
Respondent

x--------------------------x

PETITION FOR WRIT OF HABEAS CORPUS

WITH HOLD DEPARTURE ORDER
COMES NOW, Petitioner, in the above-entitled case, through the
undersigned counsel, and to this Honorable Court most respectfully
represents that:

1. Petitioner W BANGCO-OG is the mother of the minor F Bangco-

og who was born out of marriage from respondent X Britton.

2. The minor has been living with the petitioner in the house of the
latter’s mother and the minor’s grandmother since the petitioner
gave birth to F.

3. Sometime in April 20, 2024, the respondent asked permission to

visit and borrow F for a day since it is a weekend and will return
the minor before 6:00 PM. However, when the petitioner tried to
reach the respondent when it was already 9:00 PM, the respondent
is already out of petitioner’s reach and kept her incommunicado.

4. Respondent X Britton, has unlawfully removed the minor from his

lawful custodian and is currently withholding them from his lawful
guardians without just cause or legal authority.

5. The respondent’s action constitutes a violation of the minor’s

fundamental rights and is in clear contravention established legal
norms and principles.
 PRAYER

WHEREFORE, Petitioner most respectfully prays that a Writ of

Habeas Corpus be issued directing respondent to make a return showing
his legal authority to detain the minor child, subject of this petition, and
therefater, present the minor child to personally before the Court on a
date and time it chooses.

Petitioner also prays for the issuance of Hold Departure Order against X
Britton to prevent him leaving the jurisdiction until the matter is resolved
and would help the enforcement of any orders issued by the court
regarding F Bangco-og’s custody and welfare.

Baguio City, Philippines, April 27, 2024

ATTY. MELANIE S. SHERWIN

Counsel for Petitioner

Roll No. 777777

IBP No. 0000777; 05.07.2027
PTR No. CVT 0456777; 08.16.2028
MCLE Compliance No.: New Lawyer
Mobile : 09170987654
Email: melaniesherwin71@gmail.com
Republic of the Philippines )
Baguio City ) S.S.

VERIFICATION AND CERTIFICATION

OF NON-FORUM SHOPPING
I, W BANGCO-OG, Filipino, of legal age, after having been duly
sworn in accordance with law, depose and state that:

1. I am the Petitioner in the above-stated Petition for the Issuance

of Writ of Habeas Corpus;

2. I caused the preparation of the foregoing Petition;

3. I have read the contents thereof and the facts stated therein are
true and correct of my personal knowledge and/or on the basis of
copies of documents and records in my possession;

4. I have not commenced any other action or proceeding involving

the same issues in the Supreme Court, the Court of Appeals, or any
other tribunal or agency;

5. To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Regional Trial
Court, or any other tribunal or agency;

6. If I should thereafter learn that a similar action or proceeding

has been filed or is pending before the Supreme Court, the
Regional Trial Court, or any other tribunal or agency, I undertake
to report that fact within five (5) days therefrom to this Honorable
Court.

IN WITNESS WHEREOF, I have hereunto set my hand this 27th

day of the Lord, 2024 in Baguio City, Philippines.

W BANGCO-OG
Affiant

SUBCRIBED AND SWORN TO BEFORE ME this 27th day of the

Lord 2024 in Baguio City, Philippines, affiant exhibiting to me his
competent evidence of identity by way of his National ID with ID NO.
4444087372788.

Doc. No. ___;

Page No. ___; Notary Public
Book No. ___;
Series of 2024