What happens when the signor of a guaranty adds a title e.g. "president" by her signature?

I once dealt with a situation where the guarantor for a corporate debtor signed the guaranty agreement with "president" by his name. He claimed he was signing not as an individual but as a corporate representative. This usually won't do since the guaranty clearly named the individual and it made little sense for the corporate guarantor to be the corporation (the principal).

Georgia case law:


A title such as “sec.” or “CEO” signed on a guaranty is a mere word of description and the signor remains personally liable.  See O.C.G.A. § 10-6-86; Upshaw v. Southern Wholesale Flooring Co., 197 Ga. App. 511, 398 S.E.2d 749 (1990); Keane v. Annice Heygood Trevitt Support Trust, 285 Ga. App. 155, 645 S.E.2d 641 (2007).  In Upshaw, the appellant placed the abbreviation “Sec.” immediately after her signature.  The court found this to be merely descriptive as the contract was unambiguous that she was signing in her personal capacity.  Likewise, in Keane, the appellant claims he signed “CEO” after his name although it was unreadable.  The court dismissed this argument as “there is nothing in the language of the guaranty to suggest that Keane was entering the obligation as a corporate officer.”  Id.


Secondly, in both Upshaw and Keane, the court found that removing the personal liability would render the obligation meaningless “as the corporation was already obligated on the debt” and summary judgment was thus proper.  Keane at 158; Upshaw at 513.