00 payment but had no judgment rendered against it and had no liability under insurance contract where amount less than $25,000.00). A voluntary payment is "one made by a mere volunteer who pays money to another while under no legal obligation to do so or compelled to preserve some right or property of his own thereby." Cloud v. Bagwell, 83 Ga. App. 769, 64 S.E.2d 921, 925 (1951); see also Cochran v. Carpenter, 119 Ga. App. 235, 166 S.E.2d 615 (1969) (son's payment characterized as voluntary where mother paid bills of decedent from her checking account, checks were returned and mother executed note to secure checks, and son borrowed money to pay off mother's note). The key inquiry in the case at bar is whether defendant had an obligation to provide rent-free housing for her mother or to satisfy certain debts of her husband.