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