Legal Writing

Republic of the Philippines
City of Manila ) S.S
AFFIDAVIT OF LOSS
I, KATHRYN CHANDRIA MANUEL BERNARDO of legal age, Filipino, single,

and a resident of 143 Pinaglabanan Street, Sta. Cruz, Manila, after having been sworn
in accordance with law, hereby depose and state THAT:
1. I am the owner of the love issued by DANIEL JOHN FORD PADILLA on

December 25, 2016;
2. Sometime after I received the aforesaid love, I put it in my heart together with
all of his promises and locked it;
3. When I tried to open my heart, the said love was missing. I asked the people I
met along the way if they have seen or find the missing love but they
answered in negative;
4. Despite my diligent effort to look for the said love, the same proved futile.
Thus, I considered it to have been lost and beyond recovery;
5. The said love was never confiscated nor used as a security to any obligation
or transaction;
6. I am executing this affidavit to attest to the truth of the foregoing statements

and for whatever legal purpose or intents this may serve.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 24 th day

of January 2018 at City of Manila, Philippines.
KATHRYN CHANDRIA MANUEL BERNARDO

Affiant
SUBSCRIBED AND SWORN to before me on the date and place indicated

above. Affiant exhibited to me her Passport with a Passport No. P4444656A with a
validity date until 26th day of October 2022.
Doc. No. ________

Page No. ________
Book No. ________
Series of 2018
REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
Branch 5
City of Manila
IN THE MATTER OF CORRECTION OF

ENTRIES IN THE CERTIFICATE OF
LIVE BIRTH OF
JAMES CARLOS AQUINO YAP JR.
KRISTINA BERNADETTE C. AQUINO

Petitioner,
---versus--- Special Proc. No. 2018-0127
CIVIL REGISTRAR OF MANILA AND

ALL PERSONS/ENTITIES WHO/WHICH
MAY BE AFFECTED THEREBY,
Respondents.
x--------------------------------------x
PETITION
Petitioner, through the undersigned counsel and to this Honorable Court, most
respectfully states that:
1. Petitioner is of legal age, Filipino, single, a resident of Blk. 1 Lot 2 Forbes

Park, San Antonio, Makati and the mother and guardian of her minor child – JAMES
CARLOS AQUINO YAP, JR.; whereas Respondent - Civil Registrars are public officers
in-charge of the registration and cancellation/correction of entries in the civil registrar
where the fact of birth of the said minor child was registered, which registrar is located
at Ground Floor, City Hall, City of Manila;
2. Petitioner conceived and gave birth to her child – JAMES CARLOS

AQUINO YAP, JR. on April 19, 2007 at Manila Doctors Hospital, Ermita, Manila, out of
wedlock with James Carlos Agravante Yap, Sr., and was registered before the Office of
Respondent Civil Registrar of Manila under Civil Registry No. 17-1884. Copy of the
Certificate of Live Birth of James Carlos Aquino Yap, Jr. is hereto attached as Annex
“A;”
3. Prompted by the misbelief that her child, being born out of wedlock, could
not utilize the surname of her father – James Carlos Yap, Sr., and that it is more
convenient and easy to process the registration of her child’s birth if she was married
with James. Petitioner supplied erroneous information as regards the date and place of
her marriage with James Carlos A. Yap, Sr.;
4. Petitioner misrepresented in her application for the registration of birth of

her child that she and James Carlos A. Yap, Sr. were married on July 10, 2005 in
Santuario de San Antoonio Parish, Forbes Park, Makati, when the truth of the matter is
that they were and have not been married to this date. Copy of the Certification issued
by the Civil Registrar General attesting to the fact that Petitioner has not been married
to James Carlos A. Yap, Sr. as their marriage does not appear in the National Indices of
Marriage is hereto attached as Annex “B;”
5. As a result, “Entry No. 18” referring to the date and place of marriage of
the parents of the said minor child, and consequently, “Entry No. 20” particularly the
printed name of herein Petitioner which was entered as –KRISTINA BERNADETTE
AQUINO YAP, instead of KRISTINA BERNADETTE COJUANGCO AQUINO, of
Certificate of Live Birth of the child are false and misleading. Entry No. 18 in Annex A is
hereto bracketed and marked as Annex “A-1”. While, Entry No. 20 in Annex A is
further bracketed and marked as Annexes “A-2”;
6. In order to correct the aforementioned misinformation and erroneous

entries in the Certificates of Live Birth of her minor child, Petitioner hereto files the
instant Petition pursuant to Rule 108 of the Revised Rules of Court;
7. James Carlos A. Yap, Sr., the father of the above-named child, who has
been permanently residing in Quezon City did not acknowledge nor admit paternity over
the said child as he did not sign the Letter of Acknowledgment in the Certificate of Live
Birth of James Carlos A. Yap, Jr..
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed to this

Honorable Court that an Order be issued directing the herein Respondent – Civil
Registrars to cancel the information supplied as the date and place of marriage of
parents in “Entry No. 18” and to correct “Entry No. 20”, particularly the printed name
of the herein Petitioner from KRISTINA BERNADETTE AQUINO YAP to KRISTINA
BERNADETTE COJUANGCO AQUINO and to correct the surname of the minor child
from JAMES CARLOS AQUINO YAP, JR. to JAMES CARLOS AQUINO in the
Certificate of Live Birth of her minor child James Carlos.
Other reliefs just and equitable are likewise prayed for.
City of Manila. January 23, 2018.
ATTY. SOXIE TOPACIO

Counsel for the Petitioner
143 Sandico St.,Tondo, Manila, Philippines
PTR No. 0034567/Jan. 8, 2018/Manila
IBP NO. 812345/Lifetime/Manila Chapter
Attorney’s Roll No. 6012423/MCLE Compliance IV-0021531
REPUBLIC OF THE PHILIPPINES)
CITY OF MANILA )S.S
VERIFICATION AND CERTIFICATION

AGAINST FORUM-SHOPPING
I, KRISTINA BERNADETTE COJUANGCO AQUINO, single, of legal age, Filipino

and a resident of Blk. 1 Lot 2 Forbes Park, San Antonio, Makati, after having been duly
sworn to in accordance with law, do hereby depose and state that:
1. I am the Petitioner in the foregoing Petition and I have caused the

preparation of the same, the contents of which are all true and correct to the best of my
personal knowledge, information and belief;
2. I certify that neither have I commenced nor is there any pending Petition of
similar nature before any court, tribunal or quasi-judicial agency, and if I should
hereafter learn that the same or similar Petition has been filed or is pending in any
court, tribunal or quasi-judicial agency, I shall report the fact within five (5) days
therefrom to this Honorable Court.
IN WITNESS WHEREOF, I have hereunto set my hand this 23 rd day of January,

2018 in Manila.
KRISTINA BERNADETTE C. AQUINO

Affiant
SUBSCRIBED AND SWORN to before this 23rd day of January 2018, Manila. Affiant
exhibited to me her Passport with Passport No. Passport No. P5555767B with a validity
date until 13th day of January 2028.
Doc. No. ________

Page No. ________
Book No. ________
Series of 2018
Republic of the Philippine)
City of Manila ) S.S.
COMPLAINT-AFFIDAVIT
I, RICARDO DALISAY y DELA CRUZ of legal age, single, Filipino, and a

resident of 75 Malaya St., Sta Cruz, Manila, after having been duly sworn to in
accordance with law, hereby depose and state THAT:
1. I am the owner of a small merchandise store under the name and style of Ang
Probinsyano General Merchandise Store, located at 540 Commercio St,
Binondo, Manila, Metro Manila;
2. On or about 9:00 P.M. of January 13, 2018, after the inventory of the
remaining supplies and auditing of the sales from January 3 to January 13,
and before leaving my store, I asked my helper JOAQUIN TUAZON y
SYQUIA (hereinafter Joaquin), with confidence, to lock and secure the things
in the store;
3. At around 11 o’clock of the same date, I called my helper Joaquin to make

sure if he has already locked the store but he did not answer my call;
4. On January 14, 2018, at around 5 o’clock in the morning, I went to my store

and noticed that it was still locked. Using the duplicate key, I opened the store
and found out that the vault containing the sales of January 3 to January 13,
amounting to PhP 120,000.00, were missing;
5. After discovering that the sales were missing, I immediately called Joaquin
but he could not be reached. I tried to call him many times but it did not work
out.
6. Upon the review of the recorded video of the Closed-Circuit Television

(CCTV) of my store dated January 13, 2018 with timestamp of 22:45 to 23:02
(10:45 to 11:02 P.M.), it revealed that my helper, Joaquin, opened the vault
and took everything inside the vault and placed it in his bag. The copy of the
recorded video of CCTV is hereunto attached and made as an integral part
hereof as Annex “A”;
7. I immediately reported the incident on or about 6:30 in the morning at the

Manila Police District-Station 11, the nearest police station in Comercio St.,
Binondo, Manila. Original copy of the excerpt of the Police blotter issued by
SPI Bato dela Rosa of Manila Police District-Station 11 is hereunto attached
and made as an integral part hereof as Annex “B”;
8. I am executing this affidavit freely and voluntarily in support of my intent to

file case for QUALIFIED THEFT and/or the appropriate criminal case against
JOAQUIN TUAZON y SYQUIA, 30 years of age and a resident of 22
Manggagantso Street, Ermita, Manila.
IN WITNESS WHEREOF, I have hereunto set my hand this 24th day of January
2018 at City of Manila, Philippines.
RICARDO D.C. DALISAY

Complainant
SUBSCRIBED AND SWORN to before me this ___ day of January, 2018 at City
of Manila, Philippines and I FURTHER CERTIFY that I have personally examined the
affiant and I am satisfied that he has read and personally understood the contents of his
foregoing COMPLAINT-AFFIDAVIT.
____________________

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Republic of the Philippines

City of Manila ) S.S

I, KATHRYN CHANDRIA MANUEL BERNARDO of legal age, Filipino, single,

1. I am the owner of the love issued by DANIEL JOHN FORD PADILLA on

6. I am executing this affidavit to attest to the truth of the foregoing statements

IN WITNESS WHEREOF, I have hereunto affixed my signature this 24 th day

KATHRYN CHANDRIA MANUEL BERNARDO

SUBSCRIBED AND SWORN to before me on the date and place indicated

Doc. No. ________

IN THE MATTER OF CORRECTION OF

KRISTINA BERNADETTE C. AQUINO

---versus--- Special Proc. No. 2018-0127

CIVIL REGISTRAR OF MANILA AND

1. Petitioner is of legal age, Filipino, single, a resident of Blk. 1 Lot 2 Forbes

2. Petitioner conceived and gave birth to her child – JAMES CARLOS

4. Petitioner misrepresented in her application for the registration of birth of

6. In order to correct the aforementioned misinformation and erroneous

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

Other reliefs just and equitable are likewise prayed for.

City of Manila. January 23, 2018.

ATTY. SOXIE TOPACIO

VERIFICATION AND CERTIFICATION

I, KRISTINA BERNADETTE COJUANGCO AQUINO, single, of legal age, Filipino

1. I am the Petitioner in the foregoing Petition and I have caused the

IN WITNESS WHEREOF, I have hereunto set my hand this 23 rd day of January,

KRISTINA BERNADETTE C. AQUINO

Doc. No. ________

I, RICARDO DALISAY y DELA CRUZ of legal age, single, Filipino, and a

3. At around 11 o’clock of the same date, I called my helper Joaquin to make

4. On January 14, 2018, at around 5 o’clock in the morning, I went to my store

6. Upon the review of the recorded video of the Closed-Circuit Television

7. I immediately reported the incident on or about 6:30 in the morning at the

8. I am executing this affidavit freely and voluntarily in support of my intent to

RICARDO D.C. DALISAY

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