May a holder for value recover from an accommodation party notwithstanding his knowledge of such fact?


Yes, a holder for value may recover. This is so because an accommodation party is liable on the instrument to a holder for value, notwithstanding that such holder at the time of taking the instrument knew him to be only an accommodation party. The accommodation party is liable to a holder for value as if the contract was not for accommodation. It is not a valid defense that the accommodation party did not receive any valuable consideration when he executed the instrument. Nor is it correct to say that the holder for value is not a holder in due course merely because at the time he acquired the instrument, he knew that the indorser was only an accommodation party. (Ang Tiong v. Ting, G.R. No. L‐ 26767, Feb. 22, 1968)