CHAPTER X

“ACCEPTANCE”
“TANGGAPIN MO NALANG DI KA NYA GUSTO”

GROUP 2
CAPATI
CABANA
CASTULO
CASTILLO
CRUZ-HERRERA
Sec. 132. Acceptance; how made, etc. —
The acceptance of a bill is the
signification by the drawee of his assent
to the order of the drawer. The
acceptance must be in writing and
signed by the drawee. It must not
express that the drawee will perform his
promise by any other means than the
payment of money.
Meaning of acceptance
• Acceptance of a bill, as stated in Section 132, is the
signification by the drawee of his assent to the order of the
drawer.
• It has also been defined as "the act by which the drawee
manifests his consent to comply with the request contained in
the bill of exchange directed to him and it contemplates an
engagement or promise to pay."
Applicability.
• Acceptance applies only to bills of exchange and not to
promissory notes. It may be actual or constructive.
• In a certain sense it may be said that there can be no
"acceptance" of a check which is a demand instrument. In the
ordinary transaction there is no occasion for acceptance of a
check. Accordingly, Chapter X has no application to that
special kind of bill of exchange.
Object and effect of acceptance.
• (1) Unless and until he accepts, the drawee is not bound in
any way as a party to a bill and the payee or other holder has
no recourse against him even if it is shown that he had funds
in his hands belonging to the drawer sufficient to cover the
bill, and ought, in justice to the drawer, to have paid the bill.
• The object of acceptance then, is to bind the drawee and
make him an actual party liable to the instrument.
• (2) By accepting a bill, the drawee admits everything
essential to its validity. Accordingly, want or failure of
consideration cannot be shown in a suit by the payee against
the acceptor.
• (3) Until the bill has been accepted, the drawer is the
principal debtor. Upon acceptance, the bill, in effect, becomes
a note.
Formal requisites of
acceptance
• Under Section 132, actual acceptance, to be valid, must be in
writing signed by the drawee and must contain an express or
implied promise to pay money. It is necessary that the
acceptance be delivered or made known to the holder

• (1) In writing;
• (2) Signed by the drawee;
• (3) Express a promise to pay money; and
• (4) Delivered to the holder.
How acceptance made.
• Acceptance is usually made by writing across the face of the
bill the word "accepted" under which the drawee signs his
name, with the date also written.
• The law does not require any particular form of word or words
to constitute acceptance. Any equivalent word or expression
such as "honored," "seen," "presented," "good," "I would pay"
or the signature of the drawee without more is valid as
acceptance. What is important is that an intention to accept
may be inferred from the words used.
Sec. 133. Holder entitled to
acceptance on face of bill. — The
holder of a bill presenting the same
for acceptance may require that
the acceptance be written on the
bill, and, if such request is refused,
may treat the bill as dihonored.
Where acceptance may be
made.
• Acceptance may be on the bill itself or on a separate
instrument such as in a letter or telegram. Acceptance on a
separate paper may be either an acceptance of an existing bill
or an acceptance of a future or non-existing bill.
• In a constructive acceptance there is no actual written
acceptance by the drawee.
Right of holder to acceptance
on face of bill.
• Although it is not an essential requisite that an acceptance be
written on the bill, under Section 133, the holder has the right
to require that the acceptance be made on the bill itself. If the
drawee refuses, the holder has the option to treat the bill as
dishonored and go against the person secondarily liable after
giving notice of dishonor. The reason for the rule is found in
Section 134.
• Section 133 is applicable to all bills of exchange and not only
to sight bills. Although a bill payable at a fixed time need not
be presented for acceptance to charge the drawer or indorser
Sec. 134. Acceptance by
separate instrument.—Where
an acceptance is written on
paper other than the bill itself,
it does not bind the acceptor
except in favor of a person to
whom it is shown and who, on
the faith thereof, receives the
bill for value.
Acceptance by separate
instrument
• Where the acceptance is written on a paper other than the
billitself, in order to bind the acceptor, Section 134 requires
that:
• (1) the acceptance be shown to the person to whom the
instrument is negotiated; and
• (2) such person must take the bill for value on the faith of such
acceptance.
Acceptance by telegram
• The acceptance may be by telegram. But a telegram that a
draft is "good or "good for the sum named" in answer to a
telegram asking a bank if it would pay the draft is not an
"acceptance" or an agreement to accept and the drawee is
not liable as acceptor since it makes no promise to pay as such
responses are merely informative.
Sec. 135. Promise to accept; when
equivalent to acceptance. —An
unconditional promise in writing to
accept a bill before it is drawn is
deemed an actual acceptance in
favor of every person who, upon the
faith thereof, receives the bill for
value.
When promise to accept
equivalent to acceptance
• Section 134 provides that an extrinsic acceptance must be in
writing and is good only to persons to whom it is shown. On
the other hand, Section 135 provides that a promise to accept
is good to any person who "upon the faith thereof receives
the bill for value."
• The promise to accept a future non-existing bill must be
unconditional and in writing. There is a conflict of opinion as
to whether a definite description of the bill to be accepted is
essential, or whether a general agreement to accept is
sufficient, it not being necessary that the agreement be to
accept a particular bill.
Sec. 136. Time allowed drawee to
accept—The drawee is allowed
twenty-four hours after
presentment in which to decide
whether or not he will accept
the bill; but the acceptance, if
given, dates as of the day of
presentation
Time allowed drawee to
accept.
• Since the drawee by accepting the instrument becomes liable
on the bill as an acceptor, the law gives him time to make up
his mind whether to accept or reject the bill.
• Under this section, the drawee has 24 hours after
presentment for acceptance within which to act upon the bill.
However, should he decide to accept the bill, the acceptance
shall be dated as of the day of presentation or the date when
he first saw the bill
Example:
• Adrian is the holder of a bill payable 20 days after sight. If the
bill is presented for acceptance by adrian to gwen at 2:00
o'clock p.m. on September 5, gwen has up to 2:00 o'clock p.m.
of September 6 within which to accept the bill.
• Until the expiration of that time, adrian has no right to
demand an answer, nor, without categorial answer, to deem
the bill either accepted or dishonored.
• If it is accepted by gwen on September 6 the acceptance is
deemed to have been given on September 5 and, therefore,
the bill is due on September 5 and not on September 6.
Sec. 137. Liability of drawee retaining or
destroying bill. — Where the drawee to
whom the bill is delivered for acceptance
destroys the same, or refuses within
twenty- four hours after such delivery, or
within such other period as the holder
may allow, to return the bill accepted or
non- accepted to the holder, he will be
deemed to have accepted the same.
Constructive acceptance.
• This section treats of constructive acceptance by operation of
law. It should not be confused with implied acceptance which
is acceptance inferred from any act or conduct of the drawee.
(Sumcad vs. Province of Samar, 100 Phil. 72 [1956].) There is
no implied acceptance, however, under the Negotiable
Instruments Law in view of Sections 132 and 137, the decision
in the above- cited case notwithstanding.
• There is constructive acceptance: (1) where the drawee to
whom a bill is delivered for acceptance destroys it; or (2)
where the drawee refuses, within 24 hours after delivery or
within such period as is given to him, to return the bill,
accepted or non- accepted. The doctrine of constructive
acceptance is based on the general principle of estoppel.
• An accidental destruction would not be an acceptance. It must
be willfully done. (Bailey & Co. v. Veneer Co., 190 S.W. 430.)
Effect of retention of bill
• There is a conflict of authority as to whether the word
"refusal" includes mere retention of the bill by the drawee.
1. The weight of authority inclines to the view that mere
retention without refusal to return for more than 24 hours
constitutes constructive acceptance under Section 137. (Beutel's
Braririan, op. cit., p. 1249.)
2. The rule deducible from Section 150, it is believed, refers to
something of wrongful character amounting to an unauthorized
conversion of the bill by the drawee. The word "refuses" implies
that a demand for the return of the bill has been made but such
a demand was refused.
Sec. 138. Acceptance of Incomplete bill. — A bill may
be accepted before it has been signed by the drawer,
or while otherwise incomplete, or when it is overdue,
or after it has been dishonored by a previous refusal
to accept, or by non-payment. But when a bill payable
after sight is dishonored by non-acceptance and the
drawee subsequently accepts it, the holder, in the
absence of any different agreement, is entitled to
have the bill accepted as of the date of the first
presentment.
When acceptance may be
made.
• Under this section, acceptance may be made before the
bill has been signed by the drawer or while otherwise
incomplete; even after it is overdue; and even after it has
been dishonored by non-acceptance or non-payment.

1. Where bill still incomplete.

2. Where bill already overdue or has been
dishonored
Sec. 139. Kinds of acceptance. — An acceptance is either general or qualified.
A general acceptance assents without qualification to the order of the drawer.
A qualified acceptance in express terms varies the effect of the bill as drawn.

Sec. 140. What constitutes a general acceptance. — An acceptance to pay at a

particular place is a general acceptance, unless it expressly states that the bill
is to be paid there only and not elsewhere.

Sec. 141. Qualified acceptance. — An acceptance is qualified, which is —

(a)Conditional; that Is to say, which makes payment by the acceptor
dependent on the fulfillment of a condition therein stated;
(b)Partial; that is to say, an acceptance to pay part only of the amount for
which the bill is drawn;
(c)Local; that is to say, an acceptance to pay only at a particular place;
(d)Qualified as to time;
(e)The acceptance of someone or more of the drawees, but not of all.
Kinds of acceptance
• As to liability, an acceptance may be: (1) general or (2)
qualified. Both kinds of acceptance are defined in Section 139.
• "Accepted" or "good" without anything more except the
signature of the acceptor is a general acceptance as the
acceptor binds himself to pay the bill according exactly to its
tenor. The acceptance is still general although it is to pay at a
particular place. Thus, "accepted, payable at the Philippine
National Bank" is a general acceptance. (Sec. 140.) But if it
reads "accepted, payable only at the Philippine National
Bank," the same is a qualified acceptance
EXAMPLES:
• (1) Conditional. — "Received from A Co. an order from Y to
pay his note as soon as proceeds of sale of hardware is
available which I will do.“
• (2) Partial. — A bill ofPl,000.00 is accepted thus: "Accepted
for P700.00 only."
• (3) Local. —
• (4) Qualified. —A bill payable 30 days after date is accepted
thus: "Accepted 60 days from date."
• (5) As to drawee. — A bill addressed to X, Y and Z is accepted
by X and Y only,
Sec. 142. Rights of parties as to qualified acceptance.
— The holder may refuse to take a qualified
acceptance, and if he does not obtain an unqualified
acceptance, he may treat the bill as dishonored by
non-acceptance. Where a qualified acceptance is
taken, the drawer and indorsers are discharged from
liability on the bill, unless they have expressly or
impliedly authorized the holder to take a qualified
acceptance, or subsequently assent thereto. When
the drawer or an indorser receives notice of a
qualified acceptance, he must, within a reasonable
time, express his dissent to the holder, or he will be
deemed to have assented thereto.
Right of holder to general
acceptance
• A holder has a right to require a general or
unqualified acceptance and if a qualified
acceptance has been made, he may refuse
it and treat the bill as dishonored by non-
acceptance if he does not obtain an
unqualified acceptance. Accordingly, he
must notify the drawer and the indorsers
of the dishonor
CASES :
MGA TINANGGAP ANG KATOTOHANAN

PRUDENTIAL BANK VS IAC, GR No. 74886, December 8,

1992
NEW PACIFIC TIMBER & SUPPLY COMPANY INC. VS SENERIS
GR NO. L-41764, DECEMBER 19, 1980
The Phil. Bank of Commerce vs. Aruego, 102 SCRA 530
[1980].
Commercial Bank v. First National Bank, 13 A.L.R. 986.
Lawless v. Temple, 150 N.E. 176.
PRUDENTIAL BANK VS IAC, GR No. 74886,
December 8, 1992
Facts:
Philippine Rayon Mills, Inc. entered into a contract with Nissho Co.,
Ltd. of Japan for the importation of textile machineries under a five-
year deferred payment plan. To effect payment for said machineries,
Philippine Rayon Mills opened a commercial letter of credit with the
Prudential Bank and Trust Company in favor of Nissho. Against this
letter of credit, drafts were drawn and issued by Nissho, which were all
paid by the Prudential Bank through its correspondent in Japan. Two
of these drafts were accepted by Philippine Rayon Mills while the
others were not. Petitioner instituted an action for the recovery of the
sum of money it paid to Nissho as Philippine Rayon Mills was not able
to pay its obligations arising from the letter of credit. Respondent
court ruled that with regard to the ten drafts which were not
presented and accepted, no valid demand for payment can be
made. Petitioner however claims that the drafts were sight drafts
which did not require presentment for acceptance to Philippine Rayon.
Issue:

Whether presentment for acceptance of

the drafts was indispensable to make
Philippine Rayon liable thereon
Rulings:

In the case at bar, The Supreme Court Held that there was in fact no
need for acceptance as the issued drafts are sight
drafts. Presentment for acceptance is necessary only in the cases
expressly provided for in Section 143 of the Negotiable Instruments
Law (NIL). The said section provides that presentment for acceptance
must be made:

(a) Where the bill is payable after sight, or in any other case,
where presentment for acceptance is necessary in order to fix the
maturity of the instrument; or
(b) Where the bill expressly stipulates that it shall be presented
for acceptance; or
(c) Where the bill is drawn payable elsewhere than at the
residence or place of business of the drawee.

In no other case, presentment for acceptance is necessary in order to

render any party liable to the bill. Obviously then as Supreme Court
held, sight drafts does not require presentment for acceptance.
Corollarily, they are, pursuant to Section 7 of the NIL, payable on
demand. Section 7 provides:

Sec. 7. When payable on demand. — An instrument is

payable on demand —
(a) When so it is expressed to be payable on demand, or
at sight, or on presentation; or
(b) In which no time for payment in expressed.
Where an instrument is issued, accepted, or indorsed
when overdue, it is, as regards the person so issuing,
accepting, or indorsing it, payable on demand.
NEW PACIFIC TIMBER & SUPPLY COMPANY INC. VS
SENERIS GR NO. L-41764, DECEMBER 19, 1980
Facts
New Pacific Timber & Supply Company, Inc. (NPTSCI) is the defendant in a complaint for
collection of a sum of money filed by Ricardo A. Tong. On 19 July 1974, a compromise
judgment was rendered by Judge Alberto V. Seneris in accordance with an amicable settlement
entered into by the parties the terms and conditions of which are (1) that NPTSCI will pay to
Tong the amount of P54,500.00 at 6% interest per annum to be reckoned from 25 August
1972; (2) that NPTSCI will pay to Tong the amount of P6,000.00 as attorney's fees for which
P5,000.00 had been acknowledged received by Tong under Consolidated Bank and Trust
Corporation Check 16-135022 amounting to P5,000.00 having a balance of P1,000.00; (3) that
the entire amount of P54,500.00 plus interest, plus the balance of P1,000.00 for attorney's
fees will be paid by NPTSCI to Tong within 5 months from 19 July 1974; and (4) that failure on
the part of NPTSCI to comply with any of the conditions, a writ of execution may be issued by
the Court for the satisfaction of the obligation. For failure of NPTSCI to comply with his
judgment obligation, Judge Seneris, upon motion of Tong, issued an order for the issuance of a
writ of execution on 21 December 1974. Accordingly, writ of execution was issued for the
amount of P63,130.00 pursuant to which, the Ex-Officio Sheriff (Hakim S. Abdulwahid) levied
upon personal properties of NPTSCI, i.e. a unit of American Lathe 24", 1 Unit of American
Lathe 18" Cracker Wheeler, and 1 Unit Rockford Shaper 24"; and set the auction sale thereof
on 15 January 1975. The auction sale was then postponed on the following day, 16 January
1975 at 10:00 a.m. In the course of the proceedings, Deputy Sheriff Castro sold the levied
properties item by item to Tong as the highest bidder in the amount of P50,000.00. As a result
thereof, the Ex-Officio Sheriff declared a deficiency of P13,130.00. Thereafter, on 16 January
1975, the Ex-Officio Sheriff issued a "Sheriff's Certificate of Sale" in favor of Tong for the total
amount of P50,000.00 only. Subsequently, on 17 January 1975, NPTSCI filed an ex-parte
motion for issuance of certificate of satisfaction of judgment. This motion was denied by Judge
Seneris in his order dated 28 August 1975. In view thereof, NPTSCI filed the petition for
certiorari with preliminary injunction.
Issue:

Whether Tong can validly refuse acceptance of the payment of

the judgment obligation made by NPTSCI consisting of
P50,000.00 in Cashier's Check and P13,130.00 in cash which it
deposited with the ExOfficio Sheriff before the date of the
scheduled auction sale.
Rulings

The check deposited by NPTSCI in the amount of P50,000.00 is not an ordinary check but a Cashier's
Check of the Equitable Banking Corporation, a bank of good standing and reputation. As testified to
by the Ex-Officio Sheriff with whom it has been deposited, it is a certified crossed check. It is a well-
known and accepted practice in the business sector that a Cashier's Check is deemed as cash.
Moreover, since the said check had been certified by the drawee bank, by the certification, the funds
represented by the check are transferred from the credit of the maker to that of the payee or holder,
and for all intents and purposes, the latter becomes the depositor of the drawee bank, with rights
and duties of one in such situation. Where a check is certified by the bank on which it is drawn, the
certification is equivalent to acceptance. Said certification "implies that the check is drawn upon
sufficient funds in the hands of the drawee, that they have been set apart for its satisfaction, and
that they shall be so applied whenever the check is presented for payment. It is an understanding
that the check is good then, and shall continue good, and this agreement is as binding on the bank as
its notes in circulation, a certificate of deposit payable to the order of the depositor, or any other
obligation it can assume. The object of certifying a check, as regards both parties, is to enable the
holder to use it as money." When the holder procures the check to be certified, "the check operates
as an assignment of a part of the funds to the creditors". Hence, the exception to the rule enunciated
under Section 63 of the Central Bank Act to the effect "that a check which has been cleared and
credited to the account of the creditor shall be equivalent to a delivery to the creditor in cash in an
amount equal to the amount credited to his account" shall apply in the present case. Considering
that the whole amount deposited by NPTSCI consisting of Cashier's Check of P50,000.00 and
P13,130.00 in cash covers the judgment obligation of P63,000.00 as mentioned in the writ of
execution, then, the Court sees no valid reason for Tong to have refused acceptance of the payment
of the obligation in his favor. The auction sale, therefore, was uncalled for. NPTSCI's motion for the
issuance of a certificate of satisfaction of judgment is clearly meritorious and Judge Seneris gravely
abused his discretion in not granting the same under the circumstances.
The Phil. Bank of Commerce vs. Aruego,
102 SCRA 530 [1980].
Facts

On April 7 and 9, 1933, an unknown person or persons negotiated with Motor Service
Company, Inc. (MSCI), two checks in payment for automobile tires purchased from MSCI's
stores, purporting to have been issued by the 'Pangasinan Transportation Co., Inc. (Pantranco)
by J.L. Klar, Manager and Treasurer', against the Philippine National Bank (PNB) and in favor of
the International Auto Repair Shop, for P144.50 and P215.75. Said checks were indorsed by
said unknown persons in the manner indicated at the back thereof, the MSCI, believing at the
time that the signatures of J.L. Klar, Manager and Treasurer of Pantranco on both checks were
genuine. The checks were then indorsed for deposit by MSCI at the National City Bank of New
York and the former was accordingly credited with the amounts thereof, or P144.50 and
P215.75. On April 8 and 10, 1933, the said checks were cleared at the clearing house and PNB
credited the National City Bank for the amounts thereof, believing at the time that the
signatures of the drawer were genuine, that the payee is an existing entity and the
endorsements at the bank thereof regular and genuine. The PNB then found out that the
purported signatures of J.L. Klar, as Manager and Treasurer of Pantranco were forged when so
informed by the said Company, and it accordingly demanded from the National City Bank and
MSCI and the reimbursement of the amounts for which it credited the National City Bank at
the clearing house and for which the latter credited MSCI, but MSCI and National City Bank
refused, and continue to refuse, to make such reimbursements. Pantranco objected to have
the proceeds of said check deducted from their deposit. PNB filed the case in the municipal
court of Manila against National City Bank and MSCI. Upon PNB's motion, the case was
dismissed before trial as to the National City Bank. A decision was thereafter rendered giving
PNB judgment for the total amount of P360.25, with interest and costs. From this decision
MSCI appealed.
Issue

Whether the payment of the checks in question made by

the drawee bank constitutes an "acceptance", and,
consequently, the case should be governed by the
provisions of section 62 of the Negotiable Instruments
Law.
Ruling

A check is a bill of exchange payable on demand and only the rules governing bills
of exchange payable on demand are applicable to it, according to section 185 of
the Negotiable Instruments Law. In view of the fact that acceptance is a step
unnecessary in so far as bills of exchange payable on demand are concerned, it
follows that the provisions relative to "acceptance" are without application to
checks. Acceptance implies, in effect, subsequent negotiation of the instrument,
which is not true in case of the payment of a check because from the moment a
check is paid it is withdrawn from circulation. The warranty established by section
62, is in favor of holders of the instrument after its acceptance. When the drawee
bank cashes or pays a check, the cycle of negotiation is terminated, and it is illogical
thereafter to speak of subsequent holders who can invoke the warranty provided in
section 62 against the drawee. Moreover, according to section 191, "acceptance"
means "an acceptance completed by delivery or notification" and this concept is
entirely incompatible with payment, because when payment is made the check is
retained by the bank, and there is no such thing as delivery or notification to the
party receiving the payment. There can be no such thing as "acceptance" in the
ordinary sense of the term. A check being payable immediately and on demand,
the bank can fulfill its duty to the depositor only by paying the amount demanded.
The holder has no right to demand from the bank anything but payment of the
check, and the bank has no right, as against the drawer, to do anything but pay it. A
check is not an instrument which in the ordinary course of business calls for
acceptance. The holder can never claim acceptance as his legal right. He can
present for payment, and only for payment.
VIOLET MCGUIRE SUMACAD, ET AL., Plaintiffs-Appellees,
vs. THE PROVINCE OF SAMAR, ET AL.,
Facts
In May, 1942, while the province of Samar was still occupied by Japanese military forces, a
check was issued by said province to Paulino M. Santos (then the postmaster of Borongan)
for the sum of P25,000, drawn against the Philippine National Bank Cebu Branch. The payee
negotiated the check with James McGuire, an American citizen and resident of the
municipality of Borongan. After the liberation in 1946, James McGuire presented the check
to the municipal treasurer of Borongan for payment, but the latter (who merely noted it)
was not able or did not choose to pay the same. On April 25, 1950, the Philippine National
Bank requested the Bureau of Posts to furnish it with photostatic copies of the check which
were duly received by the bank on May 12, 1950. As of this date the province of Samar still
had a deposit of P84,287.47 in the Philippine National Bank. On May 14, 1950, the latter
requested James McGuire to present the check to the provincial treasurer and the provincial
auditor for certification in accordance with the circular issued by the Secretary of Finance of
July 3, 1947 on September 4, 1951, withdraw the amount of P83,504.07, leaving a balance
of only P743.43. In the meantime, James McGuire transferred his rights to the check to the
herein Plaintiffs who, unable to cash it, filed in the Court of First Instance of Samar on July
27, 1953, The position of the Appellant bank is that it did not issue the check and was
merely called upon to pay the same upon being presented for encashment if and when
funds for the purpose were available; it could not have paid said check because it was never
presented to it with the required certification under the circular of the Secretary of Finance
of July 3, 1947.
Issue:

Whether or not there is an

acceptance made by the bank?
Ruling

Yes there is an implied acceptance, as early as May 12, 1950, upon its own
request, it was furnished with photostatic copies of the check in question; and
on May 14, 1950, it went to the trouble of requiring James McGuire to present
the check to the provincial treasurer and provincial auditor for necessary
certification, it voluntarily assumed the obligation of holding so much of the
deposit of the province of Samar as would be sufficient to cover the amount of
the check, or before allowing the withdrawal that exhausted said deposit, of
making the necessary inquiry on the matter. In our opinion, an implied
acceptance of the check by the Appellant bank was thereby created. The
request by the Appellant bank from the Bureau of Posts for photostatic copies
of the check and the subsequent requirement by it for its presentation by James
McGuire to the provincial treasurer and the provincial auditor for certification,
would be an empty gesture if the Appellant did not thereby mean to assume
the obligation of paying the check and holding sufficient deposit of the drawer
for the purpose. Even so, Appellant’s resulting obligation is merely subsidiary,
the province of Samar being primarily liable to pay the check.
It being understood that the obligation of the Appellant is merely subsidiary, the
appealed decision is hereby affirmed, without costs in this instance. SO
ORDERED.
MALUPITANG TANONG:
PANO MAKAMOVE ON?

WHAT ARE THE EXCEPTIONS TO THE RULE THAT ACCEPTANCE

MUST BE WRITTEN ON THE FACE OF THE BILL?
WHY DOES ACCEPTANCE APPLIES TO BILL OF EXCHANGE ONLY
AND NOT WITH PROMISORRY NOTES?
WHAT ARE THE KINDS OF QUALIFIED ACCEPTANCE”