Separate Opinion 8 G.R. No. 224469 traditional activities, particularly the home ranges of ICCs/IPs who are still nomadic and/or shifting cultivators[.] (Emphasis and underscoring supplied) Through the IPRA, the State recognized the rights of the ICCs/IPs to their ancestral domains by virtue of native title, and such formal recognition is through the Certificate of Ancestral Domain Title (CADT), if obtained at the election of the ICCs/IPs themselves. 18 Native title is defined in the IPRA as "pre-conquest rights to lands and domains which, as far back as memory reaches, have been held under a claim of private ownership by ICCs/IPs, have never been public lands and are thus indisputably presumed to have been held that way since before the Spanish Conquest." 19 This concept of "native title" can by tra_ced back to the 1909 case of Carino v. Insular Government:2° (Carino) where the United States Supreme Court upheld the claim by an IP that the parcels of land owned by him were absolutely owned by him and his predecessors-in-interest through the years, as opposed to the Regalian Doctrine invoked by the Government of the Philippines. Thus: Whatever the law upon these points may be, and we mean to go no further than the necessities of decision demand, every presumption is and ought to be against the government in a case like the present. It might, perhaps, be proper and sufficient to say that when, as far back as testimony or memory goes, the land has been held by individuals under a claim of private ownership, it will be presumed to have been held in the same way from before the Spanish conquest, and never to have been public land. Certainly in a case like this, if there is doubt or ambiguity in the Spanish law, we ought to give the applicant the benefit of the doubt. Whether justice to the natives and the import of the Organic Act ought not to carry us beyond a subtle examination of ancient texts, or perhaps even beyond the attitudes of Spanish law, humane though it was, it is unnecessary to decide. If, in a tacit way, it was assumed that the wild tribes of the Philippines were to be dealt with as the power and inclination of the conqueror might dictate, Congress has not yet sanctioned the same course as the proper one "for the benefit of the inhabitants thereof." 21 Institutionalizing Carino was one of the principal goals in enacting the IPRA. The sponsorship speeches for the progenitor bills of the IPRA both mentioned Carino as one of the law's conceptual anchors. In his Sponsorship Speech, Senator Juan S. Flavier said: x x x [O]ur legal tradition subscribes to the Regalian Doctrine as reinstated in Section 2, Article XII of the Constitution x x x 18 19 20 21 Section 11 of the IPRA: SECTION 11. Recognition of Ancestral Domain Rights. - The rights of ICCs/IPs to their ancestral domains by virtue of Native Title shall be recognized and respected. Formal recognition, when solicited by ICCs/IPs concerned, shall be embodied in a Certificate of Ancestral Domain Title (CADT), which shall recognize the title of the concerned ICCs/IPs over the territories identified anp delineated. IPRA, Section 3 (]). 41 Phil. 935 (I 909). Id.