Republic of the Philippines

DEPARTMENT OF JUSTICE
BUREAU OF IMMIGRATION
Magallanes Drive, Intramuros
Manila 1002

IN RE: PETITION FOR LIFTING FROM THE

WATCHLISTWITH PRAYER FOR IMMEDIATE
ISSUANCE OF ORDER TO LEAVE

KWON SEONHEE as represented by

SHIN SUJEE as the Guardian,
Petitioner.
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PETITIONER

WITH DUE DEFERENCE TO THE HONORABLE BUREAU.

COMES NOW petitioner, through her guardian, and most respectfully

aver the following:

1. That petitioner Kwon Seonhee is a Korean national who is a minor

and therefore herein represented by her guardian, SHIN SUJEE who is of
legal age, single, Korean and with residence address at Lower West Mangitit,
Camp 7, Kennon Road, Baguio City;

2. That petitioner Seonhee first visited the Philippines as a tourist on

December 20, 2015 and stayed thereat for two months after which she went
back to Korea in February 25, 2016;

3. That she enrolled as a student even without the Special Study

Permit (SSP) as she was told that the lawyer of the On Go Eul English
Academy Philippines, Inc. was then processing the restoration of the
school’s accreditation with the Bureau of Immigration and so the SSP will
then be forthcoming. It was the advice of said lawyer that the school can
still accept enrollees because he had assured of the restoration of the
school’s accreditation;

4. That she again visited the Philippines for the second time in July
17, 2016 this year and was informed at the Clark Airport by the Bureau of
Immigration, through her guardian, that in the month of June 2016 she
was included in the Watch List for studying without the required permit;

5. That due to ignorance of the consequence of being in the Watch

List and considering that she was allowed entry to the Philippines despite
such list, petitioner had no inclination whatsoever that she will be barred
from going back to Korea;

6. That when she was about to go back to Korea on August 18, 2016,
she was not allowed to do so;

7. That the petitioner and her guardian went to Manila and did their
best to seek the help of the Honorable Bureau but to no avail. Attached as
Annex “A” hereof is a copy of the guardian’s handwritten letter to the
Honorable Commissioner, dated August 18, 2016;

8. That when they see that the letter was not acted upon, they went to
Clark Pampanga to plead their case but were not given favorable action;

9. That very tired, hopeless and hurting from their unfortunate

experience, they went home to Baguio only in the evening of August 19,
2016;

10. That upon advice of a friend of the guardian, said guardian and
petitioner went to seek help from the DSWD but received no help;

11. After the DSWD, petitioner and her guardian then went to the
DFA to seek help but they left the same office also empty-handed;

12. That being a minor and considering that her classes in Korea had
already started almost two weeks ago, there is an urgent need for her to go
back immediately. She missed her parents and family so much and she
was traumatized and it is clear that she badly needs counselin;

13. That for humanitarian consideration, she be allowed to leave the

Philippines and go back to Korea because, at any rate, the Government’s
interest will not be prejudiced thereby;

14. That the On Go Eul English Academy Philippines, Inc. has

undertaken to be responsible for whatever liability of the petitioner, if there
be any. Attached as Annex “B” hereof is the Affidavit of Undertaking of the
President of the said academy;

15. That, to reiterate, the petitioner was enrolled at the said academy
when she first came to the Philippines due to the fact that it was advised by
the school’s lawyer that it can accept students while said counsel is in the
process of restoring the academy’s accreditation to be followed by the
Special Student Permits of the student;

16. That such advice was fully relied upon by the said academy only
to find out that its counsel failed to perform what he promised wherein he
demanded a partial payment of Forty Thousand Pesos (P40,000.00) as
transactional fee. A copy of the deposit slip, dated December 28, 2015, to
the lawyer’s account is hereto attached as Annex “C” hereof;
 17. That said counsel cannot anymore be contacted and so the
academy is now at a loss. It is therefore asking the kind compassion of this
Honorable Bureau for its help.

PRAYER

IN WITNESS WHEREOF, it is respectfully prayed of this Honorable

Bureau to:

a. Forthwith issue an Order to Leave directing the petitioner to go

back to Korea upon receipt of this petition; and
b. Lift the name of the petitioner from the Watch List for the reason
as already presented above.

Petitioner respectfully prays for such other reliefs just and equitable
under the circumstances.

Baguio City for Manila, Philippines. August 25, 2016.

KWON SEONHEE
Petitioner

Represented by:

SHIN SUJEE
Guardian