It does "all depend".
If you are rendering the animation all in one go, then noise limit is best, as each frame will then be at a similar noise level. If you use passes or time, then as the camera moves from one room to another it may either be rendering too many passes for that room as it cleans up faster, or not rendering enough for that room if it cleans up slower. With noise limit, all the rooms will take as long as they need to get to a similar visual quality and give consistency.
But if you are dividing different rooms, scenes, camera angles up and submitting the renders for those sequences separately, you could test a single frame to find the needed number of passes for that camera angle/room/etc. and use passes.
If you absolutely can only spare 5 minutes per frame, for reasons of deadlines or machine availability, then set the time to 5 minutes. But then passes and noise may vary a lot from scene to scene and look inconsistent in the animation (but if you only have 5 mins a frame, that's all you have, and not much can be done about that in those scenarios - best to avoid those scenarios though ;) )
If time per frame is really an issue, make the most of denoising to get to a cleaner look for the image in less time. You might get away with higher denoising levels in an animation since all will be in motion and the focus is less on the absolute brilliance of the quality of each frame - best is to test a short sequence of 3 to 5 seconds and see, picking something with lots of fine detail, to see if the denoising blurs those details out too much or if that goes unnoticed while in motion. To save time testing denoising levels across short sequences, you could render to CXR and use the batch processing of the Corona Image Editor to apply different denoising levels without the need to re-render.