Romulo L. Ricafort v. Spouses Renee Roy de Guzman

Summary

This case involves a reimbursement claim under Article 1236 of the Civil Code. Petitioner Ricafort obtained a loan from PNB and signed the promissory note in his personal capacity. Deceased Spouses Roy accommodated him by allowing their property to serve as mortgage collateral through a Special Power of Attorney, but received no loan proceeds. When respondent spouses (as heirs) paid the outstanding loan to prevent foreclosure, they sought reimbursement from Ricafort. The Supreme Court affirmed that Ricafort was liable as the principal borrower and must reimburse respondents the full amount with modified interest rates in accordance with recent jurisprudence. The decision establishes the right of third parties who pay another's debt to prevent harm to seek reimbursement under Civil Code provisions.