Sample (Legal Writing)

Republic of the Philippines
City of Manila ) S.S
AFFIDAVIT OF LOSS
I, KATHRYN CHANDRIA MANUEL BERNARDO of legal age, Filipino, single, and

a resident of 143 Pinaglabanan Street, Sta. Cruz, Manila, after having been sworn in accordance
with law, hereby depose and state THAT:
1. I am the owner of the love issued by DANIEL JOHN FORD PADILLA on

December 25, 2016;
2. Sometime after I received the aforesaid love, I put it in my heart together with all of
his promises and locked it;
3. When I tried to open my heart, the said love was missing. I asked the people I met
along the way if they have seen or find the missing love but they answered in
negative;
4. Despite my diligent effort to look for the said love, the same proved futile. Thus, I
considered it to have been lost and beyond recovery;
5. The said love was never confiscated nor used as a security to any obligation or
transaction;
6. I am executing this affidavit to attest to the truth of the foregoing statements and for
whatever legal purpose of intents this may serve.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 24th day of

January 2018 at City of Manila, Philippines.
KATHRYN CHANDRIA MANUEL BERNARDO

Affiant
SUBSCRIBED AND SWORN to before me on the date and place indicated above.
Affiant exhibited to me her Passport with a Passport No. P4444656A with a validity date until
26th day of October 2022.
Doc. No. ________

Page No. ________
Book No. ________
Series of 2018
REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
Branch 5
City of Manila
IN THE MATTER OF CORRECTION OF

ENTRIES IN THE CERTIFICATE OF
LIVE BIRTH OF
JAMES CARLOS AQUINO YAP JR.
KRISTINA BERNADETTE C. AQUINO

Petitioner,
---versus--- Special Proc. No. 2018-0127
CIVIL REGISTRAR OF MANILA AND

ALL PERSONS/ENTITIES WHO/WHICH
MAY BE AFFECTED THEREBY,
Respondents.
x--------------------------------------x
PETITION
Petitioner, through the undersigned counsel and to this Honorable Court, most
respectfully states that:
1. Petitioner is of legal age, Filipino, single, a resident of Blk. 1 Lot 2 Forbes Park,
San Antonio, Makati and the mother and guardian of her minor child – JAMES CARLOS
AQUINO YAP, JR.; whereas Respondent - Civil Registrars are public officers in-charge of the
registration and cancellation/correction of entries in the civil registrar where the fact of birth of
the said minor child was registered, which registrar is located at Ground Floor, City Hall, City of
Manila;
2. Petitioner conceived and gave birth to her child – JAMES CARLOS AQUINO
YAP, JR. on April 19, 2007 at Manila Doctors Hospital, Ermita, Manila, out of wedlock with
James Carlos Agravante Yap, Sr., which fact of birth was registered on April 17, 2007 before the
Office of Respondent Civil Registrar of Manila under Civil Registry No. 17-1884. Copy of the
Certificate of Live Birth of James Carlos Aquino Yap, Jr. is hereto attached as Annex “A;”
3. Prompted by the misbelief that her child, being born out of wedlock, could not
utilize the surname of her father – James Carlos Yap, Sr., and that it is more convenient and easy
to process the registration of her child’s birth if she was married with James. Petitioner supplied
erroneous information as regards the date and place of her marriage with James Carlos A. Yap,
Sr.;
4. Petitioner misrepresented in her application for the registration of birth of her

child that she and James Carlos A. Yap, Sr. were married on July 10, 2005 in Santuario de San
Antoonio Parish, Forbes Park, Makati, when the truth of the matter is that they were and have not
been married to this date. Copy of the Certification issued by the Civil Registrar General
attesting to the fact that Petitioner has not been married to James Carlos A. Yap, Sr. as their
marriage does not appear in the National Indices of Marriage is hereto attached as Annex “B;”
5. As a result, “Entry No. 18” referring to the date and place of marriage of the
parents of the said minor child, and consequently, “Entry No. 20” particularly the printed name
of herein Petitioner which was entered as –KRISTINA BERNADETTE AQUINO YAP, instead
of KRISTINA BERNADETTE COJUANGCO AQUINO, of Certificate of Live Birth of the
child are false and misleading. Entry No. 18 in Annex A is hereto bracketed and marked as
Annex “A-1”. While, Entry No. 20 in Annex A is further bracketed and marked as Annexes “A-
2”;
6. In order to correct the aforementioned misinformation and erroneous entries in the

Certificates of Live Birth of her minor child, Petitioner hereto files the instant Petition pursuant
to Rule 108 of the Revised Rules of Court;
8. James Carlos A. Yap, Sr., the father of the above-named child, who has been
permanently residing in Quezon City did not acknowledge nor admit paternity over the said child
as he did not sign the Letter of Acknowledgment in the Certificate of Live Birth of James Carlos
A. Yap, Jr..
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed to this Honorable

Court that an Order be issued directing the herein Respondent – Civil Registrars to cancel the
information supplied as the date and place of marriage of parents in “Entry No. 18” and to
correct “Entry No. 20”, particularly the printed name of the herein Petitioner from KRISTINA
BERNADETTE AQUINO YAP to KRISTINA BERNADETTE COJUANGCO AQUINO
and to correct the surname of the minor child from JAMES CARLOS AQUINO YAP, JR. to
JAMES CARLOS AQUINO in the Certificate of Live Birth of her minor child James Carlos.
Other reliefs just and equitable are likewise prayed for.
City of Manila. January 23, 2018.
ATTY. SOXIE TOPACIO

Counsel for the Petitioner
143 Sandico St.,Tondo, Manila, Philippines
PTR No. 0034567/Jan. 8, 2018/Manila
IBP NO. 812345/Lifetime/Manila Chapter
Attorney’s Roll No. 6012423/MCLE Compliance IV-0021531
REPUBLIC OF THE PHILIPPINES)
CITY OF MANILA )S.S
VERIFICATION AND CERTIFICATION

AGAINST FORUM-SHOPPING
I, KRISTINA BERNADETTE COJUANGCO AQUINO, single, of legal age, Filipino

and a resident of Blk. 1 Lot 2 Forbes Park, San Antonio, Makati, after having been duly sworn to
in accordance with law, do hereby depose and state that:
1. I am the Petitioner in the foregoing Petition and I have caused the preparation of
the same, the contents of which are all true and correct to the best of my personal knowledge,
information and belief;
2. I certify that neither have I commenced nor is there any pending Petition of
similar nature before any court, tribunal or quasi-judicial agency, and if I should hereafter learn
that the same or similar Petition has been filed or is pending in any court, tribunal or quasi-
judicial agency, I shall report the fact within five (5) days therefrom to this Honorable Court.
IN WITNESS WHEREOF, I have hereunto set my hand this 23rd day of January, 2018 in
Manila.
KRISTINA BERNADETTE C. AQUINO

Affiant
SUBSCRIBED AND SWORN to before this 23rd day of January 2018, Manila. Affiant
exhibited to me her Passport with Passport No. Passport No. P5555767B with a validity date
until 13th day of January 2028.
Doc. No. ________

Page No. ________
Book No. ________
Series of 2018

Sample (Legal Writing)

Uploaded by

Copyright:

Available Formats

Sample (Legal Writing)

Uploaded by

Document Information

Original Description:

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Sample (Legal Writing)

Uploaded by

Copyright:

Available Formats

What is the petitioner requesting?

What is the petitioner requesting?

What information is being corrected in the birth certificate?

What information is being corrected in the birth certificate?

Republic of the Philippines

City of Manila ) S.S

I, KATHRYN CHANDRIA MANUEL BERNARDO of legal age, Filipino, single, and

1. I am the owner of the love issued by DANIEL JOHN FORD PADILLA on

IN WITNESS WHEREOF, I have hereunto affixed my signature this 24th day of

KATHRYN CHANDRIA MANUEL BERNARDO

Doc. No. ________

IN THE MATTER OF CORRECTION OF

KRISTINA BERNADETTE C. AQUINO

---versus--- Special Proc. No. 2018-0127

CIVIL REGISTRAR OF MANILA AND

4. Petitioner misrepresented in her application for the registration of birth of her

6. In order to correct the aforementioned misinformation and erroneous entries in the

WHEREFORE, premises considered, it is most respectfully prayed to this Honorable

Other reliefs just and equitable are likewise prayed for.

City of Manila. January 23, 2018.

ATTY. SOXIE TOPACIO

VERIFICATION AND CERTIFICATION

I, KRISTINA BERNADETTE COJUANGCO AQUINO, single, of legal age, Filipino

KRISTINA BERNADETTE C. AQUINO

Doc. No. ________

You might also like