Dr. John and Mrs. Jane Marquez were generous philanthropists of BG Hospital. Dr. Marquez, who bequeathed $2.8Million for the hospital, had been recognized by naming the hospital's coronary and cardiac diagnostic unit after him. The city is on the process of restructuring health care system. In response, the BG Hospital Foundation launched a campaign to raise funds to expand the hospital. Mrs. Marquez, the wife of the late Dr. John Marquez, was approached by the hospital's Chief Executive Officer to become a potential lead donor for the campaign and the suggested amount was $1Million. The foundation presented with a formal proposal that outlined the project and the hospital's interest in honouring her and the memory of Dr. Marquez by naming the new critical care unit after them. Of course, the renaming requires approval from the board of trustees. Mrs. Marquez seek the advice of her accountant and later signed the document pledging to donate $1 Million over a five-year period to the BG Hospital Foundation. She made the first instalment of $200,000 and died a month later. After Mrs. Marquis died, her estate refused to pay the balance of $800,000 owing on the pledge. Issue: Is the pledge document a contract and enforceable in law or merely "a naked promise"?