it  was  held  that  receipt  of  the  rents  was  equivalent  to  payment
of  interest  and  kept  alive  the  debt ;  and  that  it  was  immaterial
that  the  rents  and  interest  were  payable  to  different  trustees
for  the  same  person  (/). — A  receipt  signed  by  the  creditor  for
interest  due,  and  delivered  to  the  debtor  with  the  intention  of
giving  him  the  amount  was  held  to  be  equivalent  to  payment
in  taking  the  debt  out  of  the  statute,  though  no  money  in  fact
passed  {g).  An  entry  or  memorandum  made  by  the  creditor
himself  may  be  evidence  of  the  payment  after  his  death,  as
being  an  admission  made  against  his  own  interest ;  and  such
evidence  is  prima  facie  sufficient  to  take  the  debt  out  of  the
statute  {h)  ;  provided  the  entry  was  made  before  the  debt  was
barred,  for  if  made  after  it  would  operate  for,  rather  than
against,  his  interest  (*'). — A  payment  which  is  not  appropriated
by  the  debtor  at  the  time  of  making  it  to  any  particular  debt
may  be  appropriated  by  the  creditor  to  a  debt  barred  by  the
statute  ;  but  such  appropriation  by  the  creditor  has  no  effect
in  taking  the  debt  out  of  the  statute  (7i) .  Where  a  debtor
owing  three  debts,  two  of  which  were  then  barred  by  the
statute,  paid  a  sum  on  account  of  interest  generally,  it  was
held  that  he  must  have  intended  it  either  as  a  payment  upon
all  the  debts,  or  upon  the  later  only ;  and  that  the  later,  at
least,  was  renewed  by  the  payment  [1).  As  between  two
debts,  one  of  which  was  admitted  and  the  other  disputed,  a
payment  was  presumed  to  have  been  made  upon  the  admitted
debt,  though  it  was  then  barred  by  the  statute,  and  that  it
renewed  that  debt  {m).
