Sps. Salustiano Oca v. Court of Appeals

Summary

This case involves spouses Salustiano and Flora Oca who mortgaged real properties to secure a personal loan from Republic Planters Bank in 1963. The central issue was whether this mortgage could secure corporate loans extended to S.R. Oca Logging Industry Inc. The Supreme Court held that subsequent events, particularly a 1966 Board resolution authorizing consolidation of all credit accommodations and the spouses' execution of a joint promissory note with the corporation for P3,017,721.66, effectively converted the mortgage into continuing security for corporate obligations. The Court also ruled that the bank's right to foreclose had not prescribed, as written demands and acknowledgments interrupted the prescriptive period under Civil Code Articles 1142 and 1155. The decision demonstrates how personal guarantees can evolve to secure corporate debt through subsequent acts and agreements.