WRIT OF HABEAS CORPUS

Republic of the Philippines

REGIONAL TRIAL COURT
11th Judicial Region
BRANCH 35/Office of the Executive Judge
City of Makati

Juan Dela Cruz Plaintiff,

SPEC. PRO.CASE NO. ____

-versus-

MAKATI CITY POLICE OFFICE, headed by P/SR. FOR:

SUPT. Joseph Ty
HABEAS CORPUS
Respondent.
X-------------- ---------X

PETITION

PETITIONER-JUAN DELA CRUZ through counsel unto this Honorable Court most respectfully
AVERS - that:

1. PETITIONER-JUAN DELA CRUZ is 40 years old, married, Filipino and is a resident of

Barangay Guadalupe Viejo, Makati City;
2. Respondent-Makati City Police Office, headed by the City Director, P/SR. SUPT. JOSEPH
TY, with office address at Camp XYZ, Makati City;
3. On April 4, 2017, petitioner was arrested in his residence at Barangay Guadalupe Viejo,
Makati City, by agents of the Respondents-Makati City Police Office and since then
confined, restrained and deprived of his liberty in the custody of the said Police Office at
Camp XYZ , Makati City;
4. Petitioner was informed by the apprehending officers that he was arrested for violation of
section 5 of the R.A. 9165 or the Comprehensive Dangerous Drugs Act.
5. Petitioner has been deliberately deprived of his constitutionally protected freedom of
movement without valid and legal grounds; hence, this application for the writ of habeas
corpus.
 PRAYER

WHEREFORE, premises considered, it is most respectfully prayed that Respondent Makati City
Police Office, headed by P/SR. SUPT. JOSEPH TY, be directed to appear before this Honorable Court and
produce the body of petitioner, and explain forthwith why petitioner Juan Dela Cruz should not be set at
liberty without delay; and thereafter Petitioner be immediately released.

Other relief just and equitable under the premises are likewise prayed for.
Makati City, 04 April 2017.

ABC LAW OFFICES

Counsel for the Petitioner
2nd Flr. Nice Bldg., cor. Greats Village
National Highway, Makati City

By:

BILLY ILIBI
IBP Lifetime No. xxxxxx
PTR No. xxxxx
Makati City
Roll No. xxxxx
MCLE Compliance No. xxxxxxxxxxx

Verification and Certification

Jurat