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Special Raffle.

Motion for Special Raffle

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Mark Brian dela cruz
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15 views2 pages

Special Raffle.

Motion for Special Raffle

Uploaded by

Mark Brian dela cruz
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
TAGUIG CITY
EXECUTIVE JUDGE

IN THE MATTER OF THE ISSAUCNE OF A


WRIT OF HABEAS CORPUS OF WEI JIARUI,
KANG YINXI, ZHUANG CHUGEN, CHEN MIN,
LIN ZHONGSEN, LIN XINFU AND GUO YIBIN.
Petitioners

-VERSUS- Spec. Proc. No. _______________


ISSUANCE OF A WRIT OF HABEAS
CORPUS

LEANDER F. CATALO – Acting Warden


Bureau of Immigration – Warden Facility Taguig
ENS. JAMEL L. OBINIALA (PCG)
PO3 R-JAY DELA CRUZ (PCG),
PO3 DONDON DE GUIA (PCG), and
SN1 JOSHUA BAGATNAN (PCG)
Respondents.
X----------------------------------------------------X

MOTION FOR SPECIAL RAFFLE

COMES NOW Petitioners, through counsel RHYNE


YPULONG, Filipino, of legal age, with office address at 90 San
Vicente Rd., Brgy San Vicente, San Pedro Laguna and unto this
Honorable Court most respectfully avers that:

1. Petitioners move that the Petition for issuance of a Writ of


Habeas Corpus be urgently raffled;

2. Petitioners had been detained since September 17, 2024 and


despite the dismissal of their case by the City Prosecutor of
Navotas, they remain detained in the Detention Center of
the Bureau of Immigration in Camp Bagong Diwa Taguig with
no additional criminal/administrative charge.

3. The continued detention would result in grave injustice and


deprivation of their liberty.
PRAYER

WHEREFORE and in view of the foregoing Petitioners


respectfully prays that his Petition be raffled and so that the same
may be immediately heard.

10 October 2024.

RHYNE A. YPULONG
DELA CRUZ DIÑO LAW OFFICES
90 San Vicente Road., Brgy. San Vicente San Pedro Laguna
Roll No. 57169
IBP No. 210437/01.08.24
PTR No. 8410570/01.08.24/Q.C
MCLE Compliance No. VII-0021289
Atty.rhyne_ypulong@yahoo.com
09451923823

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