Republic of the Philippines

SUPREME COURT
Manila

IN RE: PETITION FOR HABEAS CORPUS

OF NAK U. LONG

NAK U. LONG,
Petitioner, S.P. NO. 1234567

-versus-

BATO DELA ROSA,

Respondent.
X---------------------------------------------/

PETITION

COMES NOW the Petitioner, by the undersigned attorney, and unto this Honorable
Court, respectfully avers:

1. That petitioner NAK U. LONG is of legal age, married and a resident of Iligan City,
Philippines, while respondent is also of legal age and may be served with summons, writs
and all orders of the Honorable Court at his office address at Philippine National Police
Iligan City Camp Tomas L. Cabili Police Department Iligan City, Philippines;

2. That the petitioner, NAK U. LONG, in whose behalf this application is being made, is
actually restrained of his liberty by the respondent BATO DELA ROSA who is the Chief of
Police of Philippine National Police- Iligan City Police Station 3;

3. That sometime in the morning of May 3, 2017, petitioner was taken into custody by the
said respondent without a warrant of arrest and detained at the Philippine National Police-
Iligan City Police Station 3 without any criminal charges being filed against him before the
proper judicial authorities despite the lapse of Twenty-four (24) Hours. Moreover,
petitioner was taken by the respondent not under any of the circumstances where a
warrantless arrest is allowed by the law or the Rules of Court;

4. That such restraint of liberty of the petitioner by the respondent is therefore without any
legal authority;

5. That the petitioner through counsel has exhausted all efforts available at law but to no
avail, and that he has no other plain, speedy, and adequate remedy to protect his personal
rights and secure his personal liberty except by his application for a Writ of Habeas
Corpus.

PRAYER

WHEREFORE, petitioner most respectfully prays that a Writ of Habeas Corpus be

issued by this Honorable Court, directed to the respondent BATO DELA
ROSA commanding the latter to produce the body of NAK U. LONG before this Court at
the time and place therein specified, and to summon the respondent BATO DELA ROSA
then and there to appear and to show cause of the detention of said NAK U. LONG; and
that after due proceedings, the said NAK U. LONG be restored of his liberty and forthwith
discharged from confinement .

Iligan City, Philippines, May 5, 2017

ATTY. JAF AMEROL

Counsel for the Petitioner
0018-B, Tibanga, Iligan City
PTR No. 12345/ 01-15-15/ Iligan City
IBP No. 54321/ 01-13-15/ Iligan City
Attorneys Roll No. 98765 1991
MCLE Compliance No. IV-0020571 June 5, 2015

VERIFICATION AND CERTIFICATION

REPUBLIC OF THE PHILIPPINES)
Ligan City...................................... ) S.S.

I, NAK U. LONG, of legal age, married and a resident of Iligan City, Philippines,
after being sworn in accordance with law, hereby depose and say:

1. That I am the (Plaintiff / Complainant / Petitioner) in the above-entitled case;

2. That I have caused the preparation of the above (Complaint / Petition) and I
have read the same and knows the contents thereof;
3. That the allegations contained therein are true and correct of my own personal
knowledge.
4. That I further certify that: (a) I have not theretofore commenced any other action
or proceeding or filed any claim involving the same issues or matter in any
court, tribunal, or quasi-judicial agency and, to the best of my knowledge, no
such action or proceeding is pending therein;
5. If I should thereafter learn that the same or similar action or proceeding has
been filed or is pending before the Supreme Court, the Court of Appeals, or any
other tribunal or quasi-judicial agency, I undertake to report such fact within five
(5) days therefrom to the court or agency wherein the original pleading and
sworn certification contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this 4th day of May 2017 at
Iligan City, Philippines.
.

NAK U. LONG
Affiant

SUBSCRIBED AND SWORN to before me this 4 th day of May 2017 at Iligan City,
Philippines.

ATTY. NOTARIO PUBLICO

Notary Public for Iligan
Unit 1, X Building, Tibanga, Iligan
Appointment No. 123, Until Dec. 31, 2016
IBP No. 123456; 01/10/10Iligan
PTR No. 1234567; 01/10/10Iligan
Roll No. 12345; 5/05/05
MCLE No. I - 001234; 9/09/15
MCLE No. II 005678; 9/09/15
Serial No. of Commission M-123
Doc. No. 1;
Page No. 1;
Book No. I;
Series of 2017