38 Decision G.R. No. 224469 agreements may be for a period not exceeding twenty-five years, renewable for not more than twenty-five years, and ~nder~such terms and conditions as may be provided by law. This doctrine is a confirmation of the State's ownership of the lands of the public domain and the patrimony of the nation. By virtue of this doctrine, the State acquired radical or underlying title to all the lands in the country. 91 This title, however, is burdened by the pre-existing legal rights of IPs who had occupied and used the land prior to birth of the State. Hence, the content of the State's underlying title is what is left when IP title is subtracted from it. 92 IP title gives the right to exclusive use and occupation of the land for a variety of purposes not confined to traditional or distinctive uses. 93 It is a beneficial interest in the land - the right to use it and profit from its economic development. But IP title is subject to the communal limitations as discussed above. 94 IP rights to preserve cultural integrity and claim or title to ancestral domains and land are subject to the State's police power. Section 77 of PD 705, as amended is an exercise of police pQwer, the validity of which is not negated by the fact that the objects thereof are owned by those charged with the offense. Rather, a police power measure is judged by the traditional test (1) "[t]he interests of the public generally, as distinguished from those of a particular class, require the exercise of the police power; and (2) [t]he means employed are reasonably necessary for the accomplishment of the purpose and not unduly oppressive upon individuals." 95 Police power trumps objections on the basis of ownership. vi. Iraya-Mangyans' practice of logging a dita tree and building a communal toilet as probably indicative of the IP right to preserve cultural integrity and to claim or title to ancestral domains or lands Iraya-Mangyans in general are settled communities. But their culture as IPs was drastically affected when they were- evicted from their ancestral domains and lands. They became nomads who had no permanent domains, until they were again re-settled pursuant to the recognition of their ancestral domains and lands. Thus: Project: Communal Toilets The Mangyan people used to be the dominant dwellers of the entire island including the lowlands, but ever since more and more foreign settlers got in and started claiming (if not grabbing) majority of the land Id. Id. 93 Id. 94 Id. 95 Acosta v. Ochoa, G.R. No. 211559, October 15, 2019. 91 92

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