Separate Concurring Opinion 22 G.R. No. 224469 would "consume their capital as well as their interests." 110 Interestingly, this sentiment from United States Government officials confirmed a degree of autonomy enjoyed by rural people, including municipal and provincial officials, away from the centralized nature of the American regime. This also revealed the erroneous perception that Filipinos who practiced swidden farming are considered as destroyers of forest resources. 111 III In 1936, Commonwealth Act No. 141 was enacted. It provides for the methods by which the government may dispose of agricultural lands, namely: "(l) [f]or homestead settlement; (2) [b]y sale; (3) [b]y lease; [and] (4) [b ]y confirmation of imperfect or incomplete titles[.]" 112 Further, as mentioned in Associate Justice Reynato Puno's separate opinion in Cruz v. Secretary ofNatural Resources: 113 Commonwealth Act No. 141 remains the present Public Land Law and it is essentially the same as Act 2874. The main difference between the two relates to the transitory provisions on the rights of American citizens and corporations during the Commonwealth period at par with Filipino citizens and corporations. 114 (Citation omitted) Amendments to Commonwealth Act No. 141 were made in 1964. Otherwise known as the Manahan Amendments, Republic Act No. 3872 introduced the following amendments to Sections 44 and 48: SECTION 1. A new paragraph is hereby added to Section 44 of Commonwealth Act Numbered One hundred forty-one, to read as follows: "SEC. 44. Any natural-born citizen of the Philippines who is not the owner of more than twenty-four hectares and who since July fourth, nineteen hundred and twenty-six or prior thereto, has continuously occupied and cultivated, either by himself or through his predecessors-in-interest, a tract or tracts of agricultural public lands subject to disposition, or who shall have paid the real estate tax thereon while the same has not been occupied by any person shall be entitled, under the provisions of this chapter, to have a free patent issued to him for such tract or tracts of such land not to exceed twenty-four hectares. 110 Ill 112 113 114 Id. Id. Com. Act No. 141, sec. 1 I. 400 Phil. 904, 941 (2000) [Per Curi am, En Banc]. Id. I