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Replacing of check did not result in novation that extinguish Salazars liability with the older check. Although NIL Sec 111 (d) state a negotiable instrument can
also be discharge By any other act which will discharge a simple contract for the payment of money which includes novation, there was no express agreement
to establish that petitioner was already discharged from his liability and acceptance of Solid Bank Check did not result to any incompatibility, since the two
checks were both for purpose to pay the same debt.