Republic of the Philippines
Name of the Aggrieved Party,
- versus - G.R. No. __________
For: Writ of Habeas Corpus
Name of Public Official or Employee
or Name of Private Person,
NOW COMES, ____________, the Petitioner, by the undersigned counsel, to this Honorable Court and respectfully represents:
That he is the mother of X, who is presently in the custody of Y, the maternal grandmother of X, who forcibly abducted X and until now actually restraints him of his liberty;
That despite demands, Y refuses to turn over the custody of X to the petitioner;
WHEREFORE, it is respectfully prayed that an order be issued to Y to bring the minor X to this Honorable Court at the hour and date to be set by this Honorable court, and thereafter that the custody of the minor X be turned over to the petitioner.
Quezon City, Philippines, this ___ day of March 2013.
NAME OF COUNSEL
Certification of Non-Forum Shopping