It sometimes happens that a promisor engages to pay the debt of another and also render some performance which is not within the Statute of Frauds. In such a case the problem is presented of how far the Statute of Frauds affects the whole undertaking. As stated in the following section, there are certain cases where the promise to pay the debt of another is wholly subordinate to other undertakings which form the main object of the contract, and where in consequence an exception has been made judicially to the Statute of Frauds; and in some jurisdictions apart from such a doctrine, an oral promise in consideration of goods or services presently furnished which includes an undertaking not only to pay for those goods, but also to pay for goods or services previously furnished to another and for which he is still indebted is enforced for the full amount.79 Such decisions, however, seem indefensible on principle since they clearly allow the enforcement of a promise to answer for the debt of another, and the consideration received is the equivalent only for part of the agreed price. As to the goods or services previously furnished, the promisor is merely a surety. Decisions of at least equal weight uphold this view.80

77 In such a case the promise seems clearly within the statute. See supra,