Answer Xyz
Answer Xyz
Answer Xyz
-versus-
x-------------------------------------------x
ANSWER
12. On October 30, 2018, the mortgagors failed to pay the Php
2,000,000.00 loan despite oral and written demands.
14. On February 16, 2019, the application was granted and the
Notice of Sale was posted in three public places of Taal Batangas
and was published once a week for at least three consecutive weeks
in a newspaper of general circulation, Copy of Notice of Sale is
attached here as Exhibit “8”.
15. On March 14, 2019, during the scheduled public auction sale
the property was sold at public auction and the highest bidder was
XYZ Lending Corporation bidding the above subject property in the
amount of Two Million Three Hundred Pesos (Php 2,300,000.00)
Philippine currency inclusive of other incidental expenses and which
amount was NOT however remitted to this office but was merely
charged/credited as full satisfaction of the mortgage obligation.
PRAYER
WHEREFORE, premises considered, it is most respectfully prays for
unto this Honorable Court that the instant complaint be dismissed on the
ground that the plaintiff has no cause of action against herein defendants
and on the counterclaim, plaintiff be ordered to pay herein answering
defendant the following:
The defendant likewise prays for other measures of relief just and
proper under the premises.
Respectfully submitted.
I, EMILIO AGUINALDO, all of legal age, all Filipino, all single, and residents of
Brgy. Calicanto, Batangas City, Batangas, after being sworn in accordance with law,
hereby depose and say:
2. That the allegations contained therein are true and correct of my own personal
knowledge and based on authentic records;
3. That we have not commenced any other action or proceeding involving the same
issue and specifically any claim involving the same issues or matter in any Court,
tribunal, or quasi-judicial agency, particularly before the Regional Trial Court; that
to the best of my knowledge, no such action or proceeding is pending in the
Supreme Court, the Court of Appeals or any other tribunal or agency, and that, if
we should learn thereafter that a similar action or proceeding has been filed or is
pending before these courts or tribunal or agency, we undertake to report that
fact to the Court within five (5) days therefrom.
EMILIO AGUINALDO
SUBSCRIBED AND SWORN to before me this 4th day of March 2021 at
Calapan City affiant exhibiting to me their government IDs.