Decision 16 G.R. No. 224469 This statement clearly exudes the bias of a colonialist regime. The notion that land ownership existed only where it adhered to civil or common law· concepts implied their acceptance at the expense of indigenous principles of ownership. While indigenous laws were not completely rejected under this formulation, only those forms of ownership which shared sufficient similarity with the civil or common law were deemed capable of securing legal protection. The original and amended versions of the current Section 77 were enacted under this exact legal framework. Hence, Section 77 could not have been so enlightened and progressive as to accord utmost respect to IP rights by excluding them from its criminal prohibition. It was only later that we were enlightened that the proper method of ascertaining IP rights necessitated a study of particular IP customs and laws. Under this test, IP rights and title are best understood by Iraya-Mangyan IPs considering indigenous history and patterns of cultural practices and land usage, rather than importing the preconceived notions of property rights under civil or common law. This enlightened view was not the text of, let alone, the intent behind Section 77. · ~ Third, as held in CF'J of Quezon (Branch VII), the intent behind the original iteration of Section 77 as then Section 68 rejected as an element of this offense, the ownership of the land from which the timber or other forest products were cut, removed, gathered, or collected, or the tim her or other forest products themselves as accessories of the land. This means that Section 68 or even Section 77 covers any type of land so long as timber or other forest products were taken therefrom, regardless of an accused's property interests in the land, when the taking was done without any authority granted by the State. It may also be inferred that mere ownership of the land does not amount to an authority granted by the State to justify the cutting, collectlon, removal. or gathering of timber or other forest products. As elucidated in CFI of Quezon (Branch VII): The failure of the information to allege that the logs taken were owned by the state is not fatal. It should be noted that the logs subject of the complaint were taken not from a public forest but from a private woodland registered in the name of complainant's deceased father, Macario Prudente. The fact that only the state can grant a license agreement, license or lease does not make the state the owner of all the logs and timber products produced in the Philippines including those produced in private woodlands. The case of Santiago v. Basilan Company, G.R. No. L15532, October 31, 1963, 9 SCRA 349, clarified the matter on ownership of timber: in private lands. This Court held therein: "The defendant has llppealed, claiming that It should not be held liable to the plaintiff because the timber which it ~ut and gathered on the land in question belongs to the government and not to the plaintiff, the latter having failed to comply with a requirement of the law with respect to his property.