Separate Opinion G.R. No. 224469 18 associations, or corporations, the officers who ordered the cutting, gathering, collection or possession shall be liable, and if such officers are aliens, they shall, in addition to the penalty, be deported without further proceedings on the part of the Commission on Immigration and Deportation. The Court shall further order the confiscation in favor of the government of the timber or any forest products cut, gathered, collected, removed, or possessed, as well as the machinery, equipment, implements and tools illegally used in the area where the timber or ~forest products are found. (Emphasis and underscoring supplied) In 1991, Sec. 68 above was eventually renumbered to Sec. 77 through R.A. 7161. 40 As regards the "authority" required by law for the cutting, gathering, and/or collecting timber or other forest products, its evolution is summarized below: E.O. No. 277 (1987) P.D. 389 (1974) P.D. 705 (1975) "permit from the Director" "any authority , "any authority" under a license agreement, lease, license, or permit" The evolution in the language of the law is not without significance. From the preceding discussion, it can be deduced that the authority required by the law has been expanded and is no longer confined to those granted by the DENR. The use of the phrase "any authority" in the law's present wording - without any qualification - ought to be construed plainly and liberally in favor of petitioners. This is in accordance with the hombook principle that penal laws shall be construed liberally in favor of the accused. 41 Moreover, applying the doctrine of casus omissus pro omisso habendus est (meaning, a person, object or thing omitted from an enumeration must be held to have been 40 41 R.A. 7161 provides: SECTION 7. Section 77 of Presidential Decree No. 705, as amended, as numbered herein, is hereby repealed. Section 68 of Presidential Decree No. 705, as amended by Executive Order No. 277 dated July 25, 1987, and Sections 68-A and 68-B of Presidential Decree No. 705, as added by Executive Order No. 277, are hereby renumbered as Sections 77, 77-A and 77-B. People v. Temporada, 594 Phil. 680 (2008).