Decision 39 G.R. No. 224469 area, most of the Mangyans were driven to the remote mountains and marshlands. Aside from losing their ancestral lands to the foreign settlers, the island's natural resources like the forests and rivers got abused causing the fast deterioration of vegetation and wildlife. These adverse developments throughout the history of the land have affected the lifestyle of the natural inhabitants - they became scavengers in their own land, they became nomads having no permanent domain, moving from place to place to survive the day. Being nomadic, their temporary settlements (haron) developed in them a culture of less desirable hygiene. This common practice in their household have cause epidemic diseases and death. But this hygiene problem was not limited to those Mangyan communities who are still nomadic because even those other communities who were blessed to be award~d with protected domains under the provision of National Council for Indigenous People (NCIP) and the local government were not able to withdraw themselves from the bad practice. [Drops of Faith Christian Missions has] seen the importance of attending to this perilous issue and so we came up with a project to start building communal toilets in those Mangyan communities which have secured dwelling permanency in their ancestral land. 96 Taking account of petitioners' distinctive culture as IPs and their displacement from the ancestral domains and land, their efforts to build communal toilets came about most likely as part of the practice intended as a means for them to survive as an ICC as result of their displacement and thereafter re-settlement. 97 • But this activity did not arise solely because of the Mangyans' dispossession of their ancestral domains and lands, though as pointed out above this may have been probably the immediate cause for the need to erect communal toilets. It has always been the case that communal structures including communal toilets have characterized the pre-colonization culture of the Mangyans. 98 The use of communal toilets has always been a cultural practice because the water source is communal and it has not been feasible to build a toilet for every household. 99 While the established cultural practice which continued from precontact and post-contact as a survival means is communal building, including those of communal toilets, the logging of the dita tree, pursuant to 96 Drops of Faith Christian Missions, at https://dfcmtribalmissions.wordpress.com/tag/mangyantribes/page/3/, (last accessed ¥arch,29, 2020). 97 Kristine Askeland, Torill Bull, Maurice B. Mittelmark, Understanding how the poorest can thrive: A case study of the Mangyan women on Mindoro, Philippines (Master's Thesis, May 2010), at http://dspace.uib.no/bitstrcarn/handle/1956/4277/69634922.pdf?sequence=l&isAlloweb (last accessed on September 21, 2020): 98 The Mangyans, Our Brothers, at http://www.newsflash.org/2004/02/tl/tl0l2695.htm (last accessed on September 21, 2020); Kapit-Bisig Laban sa Kahirapan-Comprehensive and Integrated Delivery of Social Services, at https://ncddp.dswd.gov.ph/site/feature profile/237 (last accessed on September 21, 2020); Kristine Askeland, Torill Bui!, Maurice B. Mittelmark, supra; The Iraya Mangyan Village in Puerto Galera, at http://www.mariaronabe1tran.com/2019/01/the-iraya-mangyan-village-in-puerto.html, (last accessed on March 29, 2020). 99 Id.

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