1. Pedro Makiling filed an answer to Juana Makiling's petition for a writ of habeas corpus regarding their minor daughter Maria.
2. Pedro admits some of the factual allegations but denies unlawfully detaining Maria, saying he had permission from Juana to care for Maria when she was sick.
3. Pedro prays that the petition for habeas corpus be dismissed and custody remain with him, as Maria was under a doctor's care with him.
1. Pedro Makiling filed an answer to Juana Makiling's petition for a writ of habeas corpus regarding their minor daughter Maria.
2. Pedro admits some of the factual allegations but denies unlawfully detaining Maria, saying he had permission from Juana to care for Maria when she was sick.
3. Pedro prays that the petition for habeas corpus be dismissed and custody remain with him, as Maria was under a doctor's care with him.
1. Pedro Makiling filed an answer to Juana Makiling's petition for a writ of habeas corpus regarding their minor daughter Maria.
2. Pedro admits some of the factual allegations but denies unlawfully detaining Maria, saying he had permission from Juana to care for Maria when she was sick.
3. Pedro prays that the petition for habeas corpus be dismissed and custody remain with him, as Maria was under a doctor's care with him.
1. Pedro Makiling filed an answer to Juana Makiling's petition for a writ of habeas corpus regarding their minor daughter Maria.
2. Pedro admits some of the factual allegations but denies unlawfully detaining Maria, saying he had permission from Juana to care for Maria when she was sick.
3. Pedro prays that the petition for habeas corpus be dismissed and custody remain with him, as Maria was under a doctor's care with him.
COMES NOW the respondent, by undersigned counsel, and in answer to plaintiff's petition, respectfully alleges:
1. That respondent admits paragraphs 1, 2 and 3 of the petition;
2. That respondent is without knowledge or information to form a belief as to the truth of the averments made in paragraph 4 thereof;
3. That respondent DENIES specifically each and every material allegations made in paragraph 5 of the petition, and alleges that there is no unlawful restraint by the respondent since he asked permission to the petitioner if their daughter can stay at his house for one day to celebrate the respondents birthday and pick her up from school, which the petitioner agreed and consented to it; 4. That respondent DENIES specifically the allegation made in paragraphs 6 and 7 of the petition, and alleges that respondent refused to give custody of the child to petitioner only because the child was sick and under the care and medication of respondents family doctor;
WHEREFORE, it is respectfully prayed that: (a) That the Petition for Habeas Corpus be dismissed in favor of the respondent; and (b) And for such other reliefs as may be just and equitable, and for costs.
Iligan City, July 7, 2014.
ATTY. JUAN TOTREE Counsel for the Respondent Iligan City IBP Lifetime no.______Iligan City PTR No.___________Iligan City Roll of Attorney No.____________ MCLE Compliance No.
VERIFICATION
I, PEDRO MAKILING, of legal age, do hereby state :
1. That I am the respondent in the above entitled Petition for Writ of Habeas Corpus 2. That I have caused the preparation by my counsel of said Answer to the Petition 3. That I have read the allegation therein contained, and that the same are true and correct of my personal knowledge or based on authentic records Witness my hand this 7 th day of July 2014 at Iligan City, Philippines
PEDRO MAKILING Affiant
SUBSCRIBED AND SWORN TO before me in the City of Iligan on the 7 th day of July 2014 , affiant exhibiting before me her Government Issued ID No. ___________ issued on___________________at_________________________
Notary Public Until ________________ PTR NO._____________ Issued at Iligan City On July 2,2014
Doc. No.____ Page No.____ Book No.____ Series of 2014.