Jimenez v Bucoy; G.R. No. L-10221; 28 Feb 1958; 103 Phil 40

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Petitioner-appellee presented for payment four promissory notes for different amounts totaling P21,000. The administrator-appellant manifested willingness to pay but later called attention to the fact that the notes contained no express promise to pay a specified amount.

Whether or not the notes amounted to a promise to pay the amounts indicated thereon.

YES. An acknowledgment may become a promise by the addition of words by which a promise of payment is naturally implied, such as, “payable,” “payable” on a given day, “payable on demand,” “paid… when called for.” To constitute a good promissory note, no precise words of contract are necessary, provided they amount, in legal effect, to a promise to pay. In other words, if over and above the mere acknowledgment of the debt there may be collected from the words used a promise to pay it, the instrument may be regarded as a promissory note.

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