(Caption and Title)

ANSWER

(Admissions and Specific Denials)

AFFIRMATIVE DEFENSE

That the mortgage sought to be foreclosed had already been

released by plaintiff himself, after defendant had paid One Million
Pesos (Php 1,000,000.00) of the total indebtedness of Two Million
Pesos (Php 2,000,000.00), and said released is evidenced by a
document duly signed by plaintiff, copy of which is attached hereto as
Annex/Exhibit/Attachment "X", but which has not, as yet, been ratified
and registered due to the failure of plaintiff to produce his Community
Tax Certificate / Tax Information Number.

xxx xxx xxx

-legalpassion.com-