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Urgent Motion For A Special Raffle

This document is an urgent motion filed with the Regional Trial Court of Capiz requesting a special raffle for a petition of habeas corpus. [1] The petitioner, Maelyn Arrojado, is being confined in a hospital room and not allowed to leave due to an unpaid bill, depriving her of her liberty. [2] She filed a petition for a writ of habeas corpus but the next regular raffle is not until May 2019. [3] Due to the urgency of the situation, the motion requests an immediate special raffle of the case.

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Tidong Christian Bryann
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2K views3 pages

Urgent Motion For A Special Raffle

This document is an urgent motion filed with the Regional Trial Court of Capiz requesting a special raffle for a petition of habeas corpus. [1] The petitioner, Maelyn Arrojado, is being confined in a hospital room and not allowed to leave due to an unpaid bill, depriving her of her liberty. [2] She filed a petition for a writ of habeas corpus but the next regular raffle is not until May 2019. [3] Due to the urgency of the situation, the motion requests an immediate special raffle of the case.

Uploaded by

Tidong Christian Bryann
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
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Republic of the Philippines

Province of Capiz
REGIONAL TRIAL COURT
OFFICE OF THE EXECUTIVE JUDGE
City of Roxas

IN RE: IN THE MATTER OF


THE ISSUANCE OF A WRIT
OF HABEAS CORPUS OF
MAELYN ARROJADO

MAELYN ARROJADO, S.P. No.:


Petitioner, FOR: ISSUANCE OF A
WRIT OF HABEAS
CORPUS
-versus-

ST. ANTHONY COLLEGE


OF ROXAS CITY, INC.
(HOSPITAL),
Respondent.
x------------------------------------------------------------------------x

URGENT MOTION TO CONDUCT


SPECIAL RAFFLE
PETITIONER MAELYN ARROJADO, by and through
the undersigned counsel, unto this Honorable Court most
respectfully files this Urgent Motion to Conduct Special
Raffl e and further states that:

1. Petitioner is currently being confined at Room 221


of the St. Anthony College of Roxas City, Inc.
(Hospital) located at San Roque Ext. St., Roxas City,
Capiz. Due to an unpaid hospital bill, she is not
allowed to leave from the Hospital since she
received a Discharge Instruction from her attending
physician on 16 April 2019 effectively curtailing her
freedom of movement and continuously depriving
her of her liberty without due process of law;

2. Petitioner, thus file a Petition for the Issuance of a


Writ of Habeas Corpus as a remedy for person
deprived of liberty not under any lawful process and
is continuously being illegal detained;
2

3. In view of the urgency of such Petition, there is a


need to request for the Conduct of Special Raffl e
considering that the next Regular Conduct of Raffl e
of the cases will be held on May 2019;

WHEREFORE, premises considered, it is most


respectfully prayed that the Offi ce of the Honorable
Executive Judge conduct a Special Raffl e due to the
urgency of the herein petition.

All other reliefs as are just and equitable are


likewise prayed for.

City of Roxas, 26 April 2019.

For the Petitioner,

DELA PIEZA-LAYO and TIDONG LAW


OFFICE
Inzo Arnaldo St., Roxas City

By:

CHRISTIAN BRYANN G. TIDONG


Counsel for the Petitioner
Roll No. 67286
PTR No. 5800366/12-13-17
IBP No. 039000/6-07-18
MCLE Compliance No VI-0007004/
21-03-18
09278740253

REQUEST FOR AND NOTICE OF HEARING

ATTY. SHARMEN GALLENERO- BILLONES


Branch Clerk of Court
OFFICE OF THE EXECUTIVE JUDGE
Regional Trial Court- BRANCH 18

Please submit the foregoing Urgent Motion to


Conduct Special Raffle for consideration and approval of
the Honorable Court immediately upon receipt hereof
sans oral argument.
3

ATTY. CHRISTIAN BRYANN G. TIDONG

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