Republic of the Philippines6th Judicial RegionRegional Trial CourtBranch 17Roxas City

IN THE MATTER OFTHE PETITIONFOR THEWRIT OF AMPAROIN FAVOROFJUAN DELA CRUZ,SP. PROC. NO. _________FOR: Writ of Amparo JUAN DELA CRUZ, Petitioner,

- versus

GEN. JOVITO PALPARAN,X - - - - - - - - - - - - - - - -X

PETITIONERS thru counsel, unto this Honorable Court respectfully avers that:1. Petitioner is a Filipino citizen, of age and resident of Rizal Street, Roxas City;2. Petitioner is the mother of JUAN DELA CRUZ, 25 years old and residing in the same address, in whose benefit this application is made;3. Respondent GEN. JOVITO PALPARAN is the commanding general of the Armed Forces of the Philippines, and who can be served with summons and other court processes at Camp Peralta, Jamindan, Capiz;4. Juan dela Cruz with two other companions Juanito Aquino and John Travolta were abducted and kidnapped by about 15 armed men with strong evidence of being military personnel on the early afternoon of September 15, 2014 at Brgy. Baybay, Roxas City and were forcibly brought to a place which is strongly believed to be Camp Peralta;5. Petitioner and his companions were abducted without any legal ground, authority and basis for being believed by their abductors and kidnappers to be members of the CPP - New Peoples Army;6. When Juan Dela Cruz was abducted, petitioner herein and a group of concerned citizens known as KARAPATAN reported the matter to police authorities;7. The police and the military authorities have not done anything to investigate their personnel in the commission of this dastardly crime and if any investigation was made, the investigation was shallow and pro-forma without any intention of really solving the crime;8. That petitioners herein have exhausted all efforts legally available and that there is no other plain, speedy, and adequate remedy to protect the rights of the victims except by this application for a Writ of Amparo;

PRAYERWHEREFORE, it is respectfully prayed, that:1. A writ of Amparo be immediately issued;2. An inspection Order be issued ordering the respondent to permit entry on the camp where the aggrieved party is suspected to be held, for purposes of inspection.3. Other reliefs just and equitable are likewise prayed for.

PAUL IVAN R. BATICADOSPTR # 123456,01/07/14LIFETIME MEMBER NO. 01032Bilbao Street, Roxas CityRoll # 53743MCLE Compliance# 1018, 03/12/14

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

VERIFICATION AND CERTIFICATION

I, JUANA DELA CRUZ, of legal age, Filipino and a resident of Rizal Street, Roxas City, after having been sworn to in accordance with law do hereby depose and state: That she is the mother of the abducted victim JUAN DELA CRUZ; she has caused the preparation of the above petition and has read and knows the same; the Allegations therein are true to her personal knowledge; she has not filed or commenced any action or proceedings involving the same issues nor is there any action nor proceedings before the Supreme Court, Court of Appeals, or in any tribunal or agency with the same issues and parties and in the event that petitioner would know that there is an action or proceeding involving the same issues and parties, she undertakes to notify this Honorable Court of the pendency of the said action within 5 days from knowledge thereof.

JUANA C. DELA CRUZ

SUBSCRIBED AND SWORN TO before me this 22nd day of September 2014 after petitioner exhibited to me her Voters ID No. 987653.

Notary Public