Separate Concurring Opinion 24 G.R. No. 224469 In 1977, the distinction established by the Manahan amendment was expressly abandoned by Presidential Decree No. 1073 when the latter limited the application of Section 48 (b) and (c) "to alienable and disposable lands of the public domain[.]" 118 IV After the Philippines gained its independence from the United States, the Filipino people ratified the 1935 Constitution on May 14, 1935. 119 One of the primary objectives of the framers of the 1935 Constitution was to guarantee "the nationalization and conservation of the natural resources of the country." 120 They considered it to be of great importance to ensure that the State's power of control, over the natural resources. was recognized and established. By this reason, the delegates to the Constitutional Convention adopted and incorporated Article XIII, Section 1 in the 1935 Constitution, 121 which states: SECTION 1. All agricultural, timber, and mineral lands of the public domain, waters, minerals, coal, petroleum, and other mineral oils, all forces of potential energy, and other natural resources of the Philippines belong to the State, and their disposition, exploitation, development, or utilization shall be limited to citizens of the Philippines, or to corporations or associations at least sixty per centum of the capital of which is owned by such citizens, subject to any existing right, grant, lease, or concession at the time of the inauguration of the Government established under this Constitution. Natural resources, with the exception of public agricultural land, shall not be alienated, and no license, concession, or lease for the exploitation, development, or utilization of any of the natural resources shall be granted for a period exceeding twenty-five years, except as to water rights for irrigation, water supply, fisheries, or industrial uses other than the development of water power, in which cases beneficial use may be the measure and the limit of the grant. Article XIV, Section 8 of the 1973 Constitution echoed the same prov1s10n: SECTION 8. All lands of the public domain, waters, minerals, coal, petroleum and other mineral oils, all forces of potential energy, 118 119 120 121 Pres. Decree No. 1073, sec. 4 provides: SECTION 4. The provisions of Section 48(b) and Section 48(c), Chapter VIII of the Public Land Act are hereby amended in the sense that these provisions shall apply only to alienable and disposable lands of the public domain which have been in open, continuous, exclusive and notorious possession and occupation by the applicant himself or thru his predecessor-in-interest, under a bona fide claim of acquisition of ownership, since June 12, 1945. Official Gazette, The Commonwealth of the Philippines, available at <https://www.officialgazette.gov.ph/the-commonwealth-of-the-Philippines/> (last accessed on January 5, 2020). See J. Puno, Separate Opinion in Cruz v. Secretary of Natural Resources, 400 Phil. 904, 942 (2000)[Per Curiam, En Banc]. Id.