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AMENDED PETITION FOR


CANCELLATION
SP PRO Case No.

REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
BRANCH 275
BACOOR CITY
IN
THE
MATTER
OF
CANCELLATION
OF
THE
CERTIFICATE OF LIVE BIRTH
WITH REGISTRY NO. 2069
2205 IN THE CIVIL REGISTRY
SPOUSES EDGAR P. SANTOS
AND LOURDES S. SANTOS
Petitioners,

SP PROC Case No.: 160017


AMENDED PETITION FOR
CANCELLATION

-versusTHE LOCAL CIVIL REGISTRY


OF LAS PIAS CITY and ALL
PERSONS/ENTITIES
WHO/
WHICH MAY BE AFFECTED
THEREBY,
Respondent.
x
--------------------------------------------------------------------------------------- x
Petitioner, by the undersigned counsel and unto this
Honorable Court most respectfully alleges that:
1.
Petitioners are spouses, of legal age, residing at
Block 65 Lot 1 Sampaguita St. SM Bacoor, Molino I, Bacoor
City, Cavite. Petitioner-spouses may be served with
summons and other legal process thru their undersigned
counsel;
2.
Respondent is the Local Civil Registrar and the
officer-in-charge,
among
others
with
the
officials
records/documents registered in the City of Bacoor
particularly certificates of live-birth and marriage contracts

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AMENDED PETITION FOR
CANCELLATION
SP PRO Case No.

the office of which is located in the Local Civil Registry, City


of Bacoor, where it may be served with summons and other
legal processes;
3.

The petitioners foster daughter named PIRENA


is a minor, whose birth record is recorded in the
respondents office under Registry No. 2069 2205 1;
4.Petitioner Lourdes S. Santos2, with good intentions to
take care and take Pirena as her own daughter, caused the
registration of birth of Pirena in the local civil registrar of
Bacoor City;
5.Petitioner Lourdes provided the information needed
for the registration of the birth of Pirena but the
information given are false except for the gender of the
child, hence the certificate of live birth is simulated;
6.
The information contained in the certificate of live
birth are false except for the gender of the child including
the information about the biological parents. Petitioner
Lourdes and her deceased husband in the first marriage,
Alfredo M. Marco are not the biological parents of Pirena;
13. For purposes of adoption, the Department of Social
Welfare and Development requires filing of Petition for
Cancellation if the certificate of Live Birth of the prospective
adoptee is simulated;
14. The prospective adoptee has been habitually and
continuously using the name Pirena in all her school
records and she is publicly known with that first name.
Attached herein Pirenas School Identification Card 3 and
Progress Report Card4
RELIEF
1 Machine Copy of Certificate of Live Birth of Pirena under Registry No. 2069 2205 is hereto
attached as ANNEX A

2 Hereinafter referred to as Petitioner Lourdes


3 Machine Copy of Pirena Identification Card is hereto attached as ANNEX D
4 Machine Copy of Pirena Progress Report Card is hereto attached as ANNEX E

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AMENDED PETITION FOR
CANCELLATION
SP PRO Case No.

_________
WHEREFORE, premises considered, it is most
respectfully prayed of this Honorable Court that the instant
petition be GRANTED, that the petitioner Certificate of Live
Birth with Registry No. 2069 2205 be cancelled.
Other reliefs and remedies available under the premises are
likewise prayed for.
11 April 2016. Taguig City for Las Pias City.
RESPECTFULLY SUBMITTED.