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Republic of the Philppines

Regional Trial Court


National Judicial Capital Region
Branch 105
Quezon City

Maria Christina Santos


Petitioner, Case No. 12345-QC
-vs-

Juanito Dela Cruz


Respondent
x------------------------------x

PETITION FOR HABEAS DATA

PETITIONER, respectfully alleges that:

1. Petitioner is of legal age, Filipino and resident of 10 Bughaw St., Tomas Morato, Quezon
City;

2. Respondent, Juanito dela Cruz is a Major in the Philippine Army assigned to the Intelligence
Service of the Armed Forces of the Philippines (ISAFP) with office address at Camp Aguinaldo,
Col. Bonny Serrano Ave., Quezon City, where he may be served with summons and other legal
processes;

3. The respondent has violated and is continually violating (or threatening) the privacy of
petitioner's life, liberty, security by [describe the way or method by which the respondent
violating his privacy];

4. The unlawful act of respondent mentioned in the foregoing paragraph unjustifiably affect the
petitioner's life, liberty, or security because [state the reason or reasons];

5. To protect the data or information, the petitioner has taken the following actions and
recourses: [state actions taken to protect and safeguard the data or information];

6. Presently, the files or database is located at aforementioned office and address and the person
in charge or in possession and control of the data or information is the respondent himself and/or
his subordinates.

PRAYER

WHEREFORE, petitioner prays that this Honorable Court give due course to this petition and
issue the writ of habeas data and rule, as follows:
1. Upon the filing of the petition, ENJOIN respondent from disseminating the information;
2. Upon notice and hearing, ORDER respondent to:
a. Produce the information in its possession regarding petitioner's person, his/her family, home
and correspondence;
b. Correct, suppress or destroy the information in its database, whatever may be applicable as
determined by this Honorable Court; and
c. Rectify the damage caused to petitioner's reputation by making a public apology to petitioner,
which shall be circulated in the manner and to such persons as the petitioner may deem
appropriate.

Other reliefs just and equitable under the premises are likewise prayed for.

Quezon City, Philippines, this 15th day of March 2019

Atty. Kapal Moks


Counsel for Petitioner

VERIFICATION AND CERTIFICATE OFNON-FORUM SHOPPPING

I, Maria Christina Santos of legal age, single, Filipino and a resident of 10 Bughaw St., Tomas
Morato, Quezon City, after having been duly sworn to in accordance with law, hereby, depose
and say:

1. That I am the petitioner in the above-entitled case and have caused this Petition for Habeas
Data to be prepared; that I read and understood its contents which are true and correct of my
own personal knowledge and/or based on authentic records.

2. That I have not commenced any action of proceeding involving the same issue in the Supreme
Court, the Court of Appeals or any other tribunal or agency; that to the best of my knowledge, no
such action or proceeding is pending in the Supreme Court, the Court of Appeals or any tribunal
or agency, and that, if I should learn thereafter that a similar action or proceeding has been filed
or is pending before these courts of tribunal or agency, I undertake to report that the fact to the
Court within five (5) days therefrom.

IN WITNESS WHEREFOR, I have hereunto set my hand this 15th day of March 2019.

Maria Christina Santos


Affilant

SUBSCRIBED AND SWORN to before me this 15th day of March, 2019 exhibiting her Driver's
License No. NP- 0012345 issued at Quezon City on January 15, 2019.
.
NOTARY PUBLIC
Doc. No. ______;
Page No. ______;
Book No. ______;
Series of ______;

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