G.R. No. 175025 - Jakosalem vs. Barangan

On August 13, 1966, respondent Col. Roberto S. Barangan entered into a Land Purchase Agreement with Ireneo S. Labsilica of Citadel Realty Corporation to purchase a 300-square-meter parcel of land in Antipolo, Rizal, covered by Transfer Certificate of Title (TCT) No. 165456.
Upon full payment, a Deed of Absolute Sale was executed on August 31, 1976, and TCT No. 171453 (a transfer from TCT No. 165456) was cancelled. A new title, TCT No. N-10772, was issued in Barangan’s name.
Barangan paid real property taxes but could not physically occupy the property due to his assignments as a member of the Philippine Air Force.

On December 23, 1993, Barangan discovered that the property was occupied by petitioner Godofredo Dulfo and his family.
On February 4, 1994, Barangan sent a demand letter to Dulfo to vacate the property. In response, Atty. Rogelio J. Jakosalem (Dulfo’s son-in-law) claimed ownership of the property.

Barangan filed a complaint for Violation of Presidential Decree No. 772 (Anti-Squatting Law) with the Barangay, but no settlement was reached. The case was dismissed, as the issue of ownership needed resolution in a civil action.
On May 28, 1994, Barangan commissioned a relocation survey, which confirmed that the property occupied by Dulfo was the same property covered by Barangan’s title.
On November 17, 1994, Barangan filed a Complaint for Recovery of Possession against Dulfo and Jakosalem, seeking vacation of the property, payment of monthly rental, and damages.

Petitioners claimed that the property was assigned to Jakosalem by Nicanor Samson and that they had been in possession since May 8, 1979. They also argued that the property they occupied was not the same as Barangan’s.

Barangan presented witnesses, including a caretaker who testified that Dulfo had previously rented a lot and later squatted on Barangan’s property, and a geodetic engineer who confirmed the identity of the property.
Petitioners moved for dismissal on demurrer to evidence but were denied. They later abandoned their request for an ocular inspection.

Whether Barangan was able to identify the exact location of his property under TCT No. N-10772 and whether the property occupied by Dulfo is the same property claimed by Barangan.
Whether Barangan satisfied the requirements of Article 434 of the Civil Code to recover possession.
Whether the monthly rental of ₱3,000.00 is reasonable.
Whether the grant of moral, temperate, or moderate damages and attorney’s fees is supported by evidence and law.
Whether laches and prescription barred the filing of the case.