Separate Concurring Opinion 11 G.R. No. 224469 they can catch forest animals, gather wood, bamboo, nuts, and other wild plants in the forest without the permission of other residents. 35 They can generally hunt and eat animals in the forest, except those they consider inedible, such as phytons, snakes and large lizards. 36 They employ swiddens or the kaingin system to cultivate the land within their settlements. 37 Based on the foregoing, to hold petitioners to the same standards for adjudging a violation of P.D. 705 as non-indigenous people would be to force upon them a belief system to which they do not subscribe. 38 The fact that petitioners finished up to ·Grade 4 of primary education neither negates their distinct way of life nor justifies lumping indigenous people (IP) with the rest of the Filipino people. Formal education and customary practices are not mutually exclusive, but is in fact, as some studies 39 note, co-exist in Mangyan communities as they thrive in the modem society. It may be opportune to consider that in indigenous communities, customs and cultural practices are normally transferred through oral tradition. 40 Hence, it is inaccurate to conclude that a few years in elementary school results to the total acculturation of IPs. Moreover, the degree of petitioners' education should be viewed in conjunction with the crime with which they are charged. Compared to killing or any type of assault, cutting a tree without a license is not inherently or obviously wrong as to reasonably give rise to a presumption of knowledge. Taken together with petitioners' custom of communal ownership of natural resources within their ancestral domains, it is unfair to assume that petitioners were aware that they needed to secure a permit for the logging of one (1) tree intended for their community's use, and that failing to do so would result to their incarceration. 35 36 37 38 39 ° 4 Miyamoto, Masaru, "The Hanunoo-Mangyan: Society, Religion and Law Among A Mountain People of Mindoro Island", Vol. 2. pp. iii-240. (1988). <http://scholar.google.com.ph/scholar url? url=https://minpaln1.repo.nii.ac.jp/%3Faction%3 Drepository action common download%26item id %3D3249%26item no%3D1 %26attribute id%3D18%26file no %3D l&hl=en&sa=X&scisig=AAGBfm2KgOucyQPHeh5miR8ho59QVlxnAw&nossl=l&oi=scholarr> (visited on 01 June 2020). Id. "' Miyamoto, Masaru, "Hanunoo-Mangyan Social World", Masaru Miyamoto, Vol. 2. pp. 147-195. ( 1979). <http://scholar.google.com. phischolar_url?url=https://minpaku.repo.nii.ac.jp/%3F action %3 Drepository__action_common_dow11load%26item_ id%3 D3483 %26item__110%3 D 1%26attribute_id %3D18%26file 110 %3Dl&hl=en&sa=X&scisig=AAGBfm3pY16BTL3F11BQw7litRsjPAC6MaA&nossl=l&oi=scholarr> (visited on 01 June 2020). See Recognition of Aboriginal Customary Laws (ALRC Report 31). <https://www.alrc.gov.au/publication/recognition-of-aboriginal-customary-laws-alrc-report-31 / 18aboriginal-customary-laws-and-substantive-criminal-liability/> (visited on 07 July 2020). Bawagan, Aleli, Custommy Justice System Among the Iraya Mangyans of Mindoro. 29th Annual Conference Ug11aya11g Pang-Aghamtao, Inc., 25-27 October 2007. Zamboa11ga (2007). <https ://pssc. org. ph/wp-content/pssc-archives/Aghamtao/2 009 /06 Customary%2 OJ ustice%2 0 System %20AMong%20the%20Iraya%20Mangyan's%20ofYo20Mindoro.pdf> (visited 11 September 2020). Calara, Alvaro. Ethnicity and Social A1obility in the Era of Globalization: The Journey of the SADAKI Mangyan-Alangans. ·' Philippine Sociological Review, vol. 59, 2011, pp. 87-107. JSTOR, <www.jstor.org/stable/4348637 l> (visited 11 September 2020).