Through negotiation, Emilio has received from dishonest payees two checks with the following histories:
(a) The drawer issued a check to the payee for $9.The payee cleverly altered the numeral on the check from $9 to $90 and the written word from “nine” to “ninety.”
(b) The drawer issued a check to the payee without filling in the amount. The drawer authorized the payee to fill in the amount for no more than $90.The payee filled in the amount of $900.
Discuss whether Emilio, by giving value to the payees, can qualify as a holder in due course of these checks.