Separate Concurring Opinion G.R. No. 224469 18 which revealed that almost half of the archipelago was considered public. 85 This estimate notwithstanding, only 10% of the total land mass was documented and recognized by the Spanish Regime: . The remaining portions of the private domain belonged to hundreds of thousands of people who held, or were believed to hold, undocumented customary rights or some local variation of a customary/colonial right which lacked proper documentation. 86 President William McKinley (President McKinley) then issued a directive, ordering the Philippine Commission: [T]o impose, regardless of custom, "upon every branch and division of the colonial government" the "inviolable" constitutional mandates that no person shall be deprived of property without due process of law and that just compensation be paid for all private property taken for public use[.] 87 (Citation omitted) The Taft Commission disregarded not only President McKinley's instruction, but likewise its predecessor's findings, and claimed that "Article VIII vested ownership of 92.3% of the· total Philippine land mass, or approximately 27,694,000 hectares, in the U.S. Govemment." 88 This percentage included forest lands and mineral resources, which were considered part of the public domain. In effect, the Taft Commission's estimate discounted the undocumented property rights possessed by Filipino groups over their respective ancestral lands and domains. 89 Subsequently, the United States Congress passed the Organic Act of July 1, 1902, otherwise known as the Philippine Bill. It extended to the Filipino people most of the guarantees in the American Bill of Rights which included the constitutional right not to be deprived of private property without due process of law and just compensation. 90 Section 13 of the Philippine Bill likewise authorized the Philippine Commission to promulgate rules concerning disposition of public lands. 91 Section 14 85 86 87 88 89 90 91 Owen James Lynch, Jr., Invisible Peoples and a Hid.den Agenda: The Origins of Contemporary Philippine Land Laws, 63 PHIL. L. J. 249, 250 (1988). Id. Id. at 250-251. Id. at 251. Owen James Lynch, Jr., Invisible Peoples and a Hidden Agenda: The Origins of Contemporary Philippine Land Laws, 63 PHIL. L. J. 249,250 (1988). Owen James Lynch, Jr., Native Title, Private Right and Tribal Land Law: An Introductory Survey, 57 PHIL.L. J. 268,276 (1982). Philippine Bill of July 1, 1902, sec. 13 provides: SECTION 13. That the Government of the Philippine Islands, subject to the provisions of this Act and except as herein provided, shall classify according to its agricultural character and productiveness, and shall immediately make rules and regulations for the lease, sale, or other disposition of the public lands other than timber or mineral lands, but such rules and regulations shall not go into effect or have the force of law until they have received the approval of the President, and when approved by the President they shall be submitted by him to Congress at the beginning of the next ensuing session thereof and unless disapproved or amended by Congress at said session they shall at the close of such I