Republic of the Philippines

Regional Trial Court

City of Manila
Branch 24

KING MARCUS
no. 1699

Civil

Case

QUEEN PRIMROSE
a minor

Custody of

Plaintiff,
-versusGOTHEL WITCH
Defendant.

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COMPLAINT
COMES NOW, the plaintiff together with the undersigned counsel to
this most honorable court, MOST RESPECTFULLY STATES THAT;
1. Plaintiffs KING MARCUS and QUEEN PRIMROS are of legal age, married and
resident of Stasi Castle, Neverland. The Defendant GOTHEL WITCH is of
legal age, single and resident of Witch Lock Ville, Neverland.
2. The relationship of plaintiffs to the child is that of Mother and Father.
3. On February 13, 2001, 2:30 AM, QUEEN PRIMROSE, gave birth to a baby
girl named RAPUNZEL.
4. On February 15, 2001 QUEEN PRIMROSE was walking RAPUNZEL with a
stroller along the backyard of their house, then she felt thirsty and went
inside to drink water then when she came back she saw GOTHEL WITCH
running away with her daughter RAPUNZEL.
5. Plaintiffs reported the incident to the local police in Stasi Castle, Neverland
but the policemen found the house of GOTHEL WITCH abandoned.
6. Fourteen years of searching plaintiffs saw RAPUNZEL was imprisoned in a
High tower at GOTHEL WITCH residence at Witch Lock Ville, a remote
locality in the Municipality of Neverland.
7. Plaintiffs made several demands to the defendant to return their daughter
but the defendant ignored the demands.
8. The defendant threatened the plaintiffs all of you will die before you can
take RAPUNZEL away from me
9. Plaintiffs seek legal custody of RAPUNZEL, minor age, resident of Witch
Lock Ville, Neverland. The child is presently in custody of GOTHEL WITCH.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court the judgment be rendered in favor of the plaintiffs and
that after judgment.
1. Defendant shall give the custody to the plaintiffs.
2. Defendant shall be ordered to pay for moral and exemplary damages, and
attorneys fees.
Such other reliefs and remedies under the premises are likewise prayed for.
VERIFICATION AND CERTIFICATION
We, KING MARCUS and QUEEN PRIMROSE plaintiffs, of legal age, married, Filipino
citizen and a resident of Stasi Castle, Neverland, after being sworn according to law,
hereby depose and state that;
1. That we caused the preparation of the foregoing complaint;
2. We have read the contents thereof and the facts stated therein are true
and correct of our personal knowledge and/or on the basis of copies of
documents and records in my possession;
3. We have not commenced any other action or proceeding involving the
same issues and specifically the same check/s in the Supreme Court, the
Court of Appeals or any other tribunal or agency; that to the best of our
knowledge, no such action or proceeding is pending in the Supreme Court,
the Court of Appeals or any other tribunals or agency; that if we should
thereafter learn that a similar action or proceeding has been filed or is
pending before the Supreme Court, the Court of Appeals, or any other
tribunal or agency, I undertake to report that fact within five (5) days
therefore to his Honorable Court.

KING MARCUS

QUEEN

PRIMROSE

SUBSCRIBED AND SWORN to before me this 3rd day of August 2015 at

Manila City affiants exhibiting Community Tax Certificate No. 1515 issued 15 th of
July.
Doc. No.; 25
Page No.; 7
Book No.; 2
Series of 2015

Atty. Angelique Arca

Villaruel

Atty. FC Cartagena

Atty. Ariz

Atty. Ceazar Menor

Atty. Basri Jay Sakkahalul

Copy furnished;
Atty.
Atty.
Atty.
Atty.

John Earl Loredo

Jose Carlos Garcia
Rolando Nuval
Ronillo Pulmano

EXPLANATION
Copy of the foregoing complaint was served to the defendants counsel by
registered mail due to time and distance constraints and lack of manpower that can
serve the time.