Republic of the Philippines

SUPREME COURT



IN THE MATTER OF THE PETITION
FOR THE WRIT OF AMPARO IN FAVOR
OF JUANA CHANGE, ON BEHALF OF HER
DAUGHTER MARIA CHANGE

SP. PROC. NO. _________
FOR: Writ of Amparo
Juana Change, on behalf of her daughter
Maria Change, Petitioner,

- versus -
Lt. Gen. Maxillano Vitug, Defendant
X - - - - - - - - - - - - - - - - - - - - - - - - - - /

PETITION FOR THE WRIT OF OF AMPARO

PETITIONER, through Counsel, and unto this Most Honorable Court, respectfully avers:
1. That Maria Change is the daughter of Juana Change, Filipino citizen of legal age,
married to Juan Change and a resident of Barangay Bato, Sta. Cruz, Davao del Sur.
2. That that on September 17 2013 at around 8:00 p.m, Maria Change were catching
frogs outside their home in Barangay Bato, Sta. Cruz, Davao del Sur.
3. That Juana Change went out to check on Maria Change at around 2: 00 a.m. of 18 of
September 2013, but only saw Marias cap, slippers, pana and airgun for catching
frogs, as well as bloodstains.
4. That Maria Change immediately reported the matter to the barangay officials.
5. That. of September 17, 2013, Nicolas, a resident of Barangay Bato, who were then at
home, heard gunshots and saw armed men in soldiers uniforms passing by that at
around 1:00 a.m. of the same day Maria Change went missing.
6. That Josephine (sister in law of Juana Change) informed Juana that she saw Maria
Change on September 24, 20013 and November 1, 2013 at the Camp of the Bravo
Company of the Armys 71st Infantry Batallion.
7. That Maria Changes life, liberty and security had been and continued to be violated
on account of her forced disappearance.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court
that judgment be rendered in favor of the plaintiff and that:
a. A writ of Apmaro be issued;
b. The inspection of Camp of the Bravo Company of the Armys 71st Infantry
Batallion. be ordered;
c. Issuance of temporary and permanent protection orders

Digos City, Philippines, this 18
th
day of September 2014.

Atty. Charlotte F. Gallego
Counsel for the Plaintiff
PTR No. 1020304050:B.C.
IBP No, 1234567:B.C.
Roll No. 1234:5-10-21: Digos

















VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )
City of Digos ) S.S.

I, JUANA CHANGE, of legal age, Filipino citizen, married and resident of Barangay Bato, Sta.
Cruz, Davao del Sur, after having been duly sworn to in accord Nance with law do hereby
depose and say:
That I am the plaintiff in the above-entitled case;
That I have caused the preparation of the foregoing complaint and have read the
allegations contained therein;
The allegations in the said complaint are true and correct of my own knowledge and
authentic records;
I hereby certify that I have not commenced any other action or proceeding involving the
same issues in any court, tribunal or quasi-judicial agency and, to the best of my
knowledge, no such other action or claim is pending therein;
That if I should learn thereafter that a similar action or proceeding has been filed or is
pending, I hereby undertake to report that fact within five (5) days therefrom to the court
or agency where the original pleading and sworn certification contemplated herein have
been filed;
I executed this verification/certification to attest to the truth of the foregoing facts and to
comply with the provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 24th of September
2012, in the City of Digos.

JUANA CHANGE
SUBSCRIBED AND SWORN to before me this _______ day of September, 2012, in the City of
Digos, affiant exhibiting to me his Drivers License No. 01234 issued by the Land
Transportation Office on April 8, 2012 at the City of Manila.

Atty. Charlotte F. Gallego
Counsel for the Plaintiff
PTR No. 1020304050:B.C.
IBP No, 1234567:B.C.
Roll No. 1234:5-10-21: Digos