REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 13, QUEZON CITY

In the matter of the

Petition for Issuance of Writ of
Habeas Corpus

Patrick Oliveros,
Petitioner,

- versus - SP NO. ____________

Leticia Soliman
Respondent.

x -----------------------------x

JUDICIAL AFFIDAVIT

OFFER OF TESTIMONY:
The testimony of witness PATRICK OLIVEROS is being offered for the following
purposes:

1. To prove that the petitioner PATRICK OLIVEROS is the parent of minor PATRICE
OLIVEROS who has parental authority and legal custody over the same;
2. To prove that on March 4, 2017, the respondent LETICIA SOLIMAN unlawfully
deprived the petitioner of his custody over his daughter, PATRICE OLIVEROS.
3. To prove that despite continuous demands through calls and letter, Leticia
refuses to turn over the custody of Patrice and continuously restraints her liberty
to see or contact the petitioner.
4. To prove all allegations in the complaint;
 I, Partick Oliveros, of legal age, married, and a Filipino citizen residing at
1234 Butmbakal St. Brgy San Agustin, Quezon City , after being duly sworn to in
accordance with law, hereby depose and state that:

PRELIMINARY STATEMENT

I am being questioned by Atty. Justine Mikaela Tria in her Law Office located in
14213 Golden State Building 840 Maharlika St., Quezon City. I am answering her
questions fully conscious that I do so under oath and may face criminal liability for false
testimony.

QUESTIONS AND ANSWERS

Q1: STATE YOUR NAME AND PERSONAL CIRCUMSTANCES.

A1: I am PATRICK OLIVEROS, father of PATRICE OLIVEROS and the petitioner in this
case against Leticia Soliman.

Q2: DO YOU KNOW THE ACCUSED IN THIS CASE

A2: Yes Ma’am, LETICIA SOLIMAN is my mother-in-law. She is the grandmother of my
daughter Patrice; LETICIA soliman is the mother of Patricia as evidenced by Patricia –
my deceased wife, marked as “ANNEX C” and in Patrice’s birth cerficate, it is written
there that I am the father, Patrice’s birth certificate is marked as “ANNEX B”

Q3: DO YOU HAVE PROOF OF YOUR MARRIAGE TO PATRICIA OLIVEROS

A3: Yes Ma’am, I presented my certificate of marriage marked as “ANNEX A”

Q4: WAS THERE ANYTHING EVENTFUL THAT HAPPENED ON JANUARY 10, 2017?
A4: Yes Ma’am, my wife Patricia Oliveros died due to an accident, She left me and our
daugther Patrice, and she is now beside God in His loving embrace looking down upon
us from heaven.

Q5: AND WHAT HAPPENED AFTER PATRICIA’S DEATH?

A5: Aside from the funeral, Patricia’s mother Leticia wrote me a letter asking me if she
could take care of my dauther and her grand daughter, so that she will be able to make
sure that my daughter and her grand daughter will be raised well to the high standards
of society, that she will make sure she is educated and has manners and good graces.
The letter is marked as “ANNEX E”

Q6: WAS THERE ANYTHING EVENTFUL THAT HAPPENED ON MARCH 4, 2017?

A6: Yes Ma’am, when I came home from work, I discovered that my daughters clothes
and belongings were no longer at our home, the same can be said for the clothes and
belongings of my mother in law Leticia, I contacted our relativesa and found out that
Leticia took Patrice to her house in cavite, the print out of the text messages and call log
is marked as “Annex F”

Q7: WHAT DID YOU DO THERE AFTER OR WHAT DID YOU DO THE NEXT DAY
MARCH 5, 2017?
A7: I went to Cavite to Legaspi Village where my Mother-in-Law or Monster-in-Law is
residing and I had the intention to get my daughter and bring her home, however the
village gaurds informed me that I am not allowed to enter the Village upon orders of
Leticia, and that I may not enter the Village on that day nor any other day. The testimony
of the village guard Ernesto Prieto is marked as “ANNEX G” and my affidavit of the
events that transpired on March 5, 2017 is marked as “ANNEX H”

Q8: WHAT DID YOU DO AFTER THIS?

A8: I pleaded to my Mother-in-Law” or “Monster-in-Law” and beggged her to give back
custody of my daughter Patrice, she is the light in my life, and the best reminder I have
of my Wife Patricia, She I sall I have left. Without my family, without my daughter I am
nothing. That is why I wrote a demand letter asking my Mother-in-Law to return my
daughter back to me, I am sure that my Wife Patricia would want me to take care of our
daughter. The letter is marked as “ANNEX I”

Q9: WHAT DO YOU WANT TO HAPPEN IN THIS CASE?

A9: I want the Honorable Court to issue a Writ of Habeas Corpus for me to have the
custody of my daughter.

Q10: DO YOU CONFIRM AND AFFIRM THE TRUTHFULNESS AND VERACITY OF

THE ABOVE STATEMENTS?

A10: YES Ma’am.

Signed this ___th day of _______________in the City of ___________, Philippines.

PATRICK OLIVEROS
ID No. ____________

SUBSCRIBED and sworn to before me this ___th day of ______________ in the City of
__________ affiant exhibiting to me id as above indicated, known to me and to me known to be
the same person who executed this instrument of his own free will and volition.

NOTARY PUBLIC
Doc no
Page no
Book no
Series of 2017

ATTESTATION
The undersigned ATTY. JUSTINE MIKAELA TRIA,of legal age, single, and with law
office address 14213 Golden State Building 840 Maharlika St., Quezon City, under
oath, deposes and states:

1. She is the Legal Counsel for the petitioner in the above-entitled case;

2. She faithfully recorded or caused to be recorded the questions he asked

and the corresponding answers that the above-named witness gave;

3. Neither she nor any other person then present or assisting him coached the
witness regarding the latter's answers; and

4. She conducted the examination of the witness at her law office located at
14213 Golden State Building 840 Maharlika St., Quezon City.
ATTY. JUSTINE MIKAELA TRIA
Affiant