Petitioner made a money market placement with the Philippine Underwriters Finance Corporation (Philfinance) for which he was issued, among others, a Certificate of Sale of one Delta Motors Corporation (Delta) promissory note with Philfinace as “payee” and Delta as “maker,” and on the face of the said note was stamped “NON-NEGOTIABLE.” Despite repeated demand, petitioner failed to collect his investment and interest thereon.
Whether or not a non-negotiable is capable of assignment or transfer.
YES. A non-negotiable instrument may not be negotiated, but it may be assigned or transferred, absent an express prohibition against assignment or transfer written in the face of the instrument. A promissory note marked “non-negotiable” but not at the same time stamped “non-transferrable” or “non-assignable” may be assigned or transferred.