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Letter To PARO Figueroa

This letter is from the law office of Malunes, Mampang & Montoro representing Gabriel Bongco's wife and children regarding land owned by Bongco. The letter requests that the protest filed in 2016 regarding coverage of the land under the Comprehensive Agrarian Reform Program be resolved, as it has been over 3 years with no resolution. The letter argues the land should be exempt as it received development permits before 1988 and is now urbanizing. However, another survey plan was mysteriously approved for the same land despite an existing plan, further complicating matters.

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0% found this document useful (0 votes)
474 views2 pages

Letter To PARO Figueroa

This letter is from the law office of Malunes, Mampang & Montoro representing Gabriel Bongco's wife and children regarding land owned by Bongco. The letter requests that the protest filed in 2016 regarding coverage of the land under the Comprehensive Agrarian Reform Program be resolved, as it has been over 3 years with no resolution. The letter argues the land should be exempt as it received development permits before 1988 and is now urbanizing. However, another survey plan was mysteriously approved for the same land despite an existing plan, further complicating matters.

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Omnibus Musc
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© © All Rights Reserved
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MALUNES, MAMPANG & MONTORO

LAW OFFICE
Room 304, Park Lane Building
Hilado-Tindalo Avenue, Shopping Center, Bacolod City
Tel. No. (034) 700-9296/709-0080
---o0o---

February 07, 2020

ARNULFO T. FIGUEROA
PARPO II, Negros Occidental South
Province of Negros Occidental

Sir:

I am writing to you on behalf of my client, GABRIEL L. BONGCO who is


now deceased and is survived by his wife, MARITES BONGCO, and their
minor children.

My client is the landowner of several landholdings in Bago City, Negros


Occidental, covered by TCT No. 14826, TCT No. 14825 and TCT No.14835, which
has a total area of 130.66 hectares more or less. These landholdings were
subjected to CARP coverage.

On October 4, 2016, we filed our protest with an application for


exemption/exclusion from the CARP coverage of said landholdings on the
following basis:

1. A Development Permit for subdivision development was issued as early


as June 10, 1988, or before the effectivity of the CARP law, by the then
Human Settlements Regulatory Commission now, Housing and Land
Use Regulatory Board (HLURB).

2. The area was already certified by the Bago City Zoning Administrator
that it is located within the Medium Density Residential District of the
city prior to the effectivity of the CARP law on June 15, 1988.

3. There was already a DAR clearance issued on May 20, 1988, that is,
prior to the effectivity of the CARP law which took effect only on June
15, 1988.

4. As of now, there exists a hospital in a portion of TCT No. 14835.

5. The Notice of Coverage over TCT No. T-14835 was received by Atty.
Lacson and not by the landowner himself hence the service is defective.

6. The area is now urbanizing as it is just in the heart of the City of Bago
and developments are sprouting in the area.

It has been three (3) years and four (4) months now since the filing of their
protest but the protest remains unresolved up to this writing despite our repeated
follow-ups via conferences and in writing.

Meanwhile, despite our representation and insistence that the landholding


has been already issued a development permit before the effectivity of the CARP
MALUNES, MAMPANG & MONTORO
LAW OFFICE
Room 304, Park Lane Building
Hilado-Tindalo Avenue, Shopping Center, Bacolod City
Tel. No. (034) 700-9296/709-0080
---o0o---

Law in 1988, the PARO, MARO and the LBP are maneuvering to acquire the
property by all means.

Just recently, our client learned that another approved survey plan was
mysteriously issued, under BCS-06-000270 (AR), over the said landholding at
the instance of your office DESPITE of the non-cancellation and existing
approved subdivision plan under PCS-06-001139. In short, for the same
landholding, there are now two (2) approved survey plans which even more
complicates the matter.

It is worth stressing that the approved subdivision plan was issued on May
29, 1991 by the Human Settlement Development Permit (HSDP)

ARIEL I. MALUNES
Counsel for Bungco
Copy furnished:

Office of the Secretary Date of Mailing _____________


Department of Agrarian Reform Registry Receipt_____________
Elliptical Road, Dilliman, Quezon City

Teresita R. Mabunay Date Received:______________


Provincial Agrarian Reform Officer Received by ________________
DAR, Bacolod City

Municipal Agrarian Reform Officer Date of Mailing _____________


Bago City, Negros Occidental Registry Receipt _____________

The Land Bank of the Philippines Date Received: ______________


Bacolod City Branch, Bacolod City Received by:________________

Agrarian Services Group Date of Mailing: _____________


Land Bank of the Philippines Registry Receipt _____________
Landbank Plaza, 1598 MH Del Pilar
Cor. Dr. Quintos St., Malate, Manila, 1004

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