2001 Bar: What should Mario state in his motion in order to justify the setting aside of order of default? (3%)

2001 Bar: Mario was declared in default but before judgment was rendered, he decided to file a motion to set aside the order of default. What should Mario state in his motion in order to justify the setting aside of order of default? (3%)
So as to justify the setting aside of the order of default, Mario should state in his motion that his failure to answer was due to fraud, accident, mistake or excusable negligence and that he has a meritorious defense (Sec. 3[b], Rule 9).