Separate Concurring Opinion ' 17 GR. No. 224469 Any claim to such lands by those who might have applied for adjustment of the same but have not done so at the time of the above-mentioned date, will not avail themselves in any way or at any time. 78 The Maura law imposed a unilateral registration deadline 79 to all natives for their customary claims over their lands, otherwise, their land will be taken away or confiscated by the Crown. 80 In a sense, it was the first law which empowered the Spanish government to deny legal recognition of the native' s customary property rights. It was a manifestation of "the colonial regime's insensitivity to the plight and potentials of the masses." 81 The law's effects, based on wrong premises, proved to be enduring. It was later used by the American colonizers as basis to deny recognition of ancestral property rights. Further, the law became the foundation for what will be the known as tBe Regalian Doctrine in modern times. 82 II On the international scale, war broke out between Spain and the United States of America. Spain surrendered on May 1, 1898, and the United States was set to secure a sovereign claim over the Philippines. 83 On December 10, 1898, Spain ceded the Philippines to the United States through the Treaty of Paris. The Treaty provided that all immovable properties which, in conformity with law, belonged to the Crown of Spain, had been relinquished and ceded to the United States. Nevertheless, Article VIII of the Treaty recognized that, "the relinquishment and cession ... cannot in any respect impair the property rights which by law belong to peaceful possession. " 84 In 1899, the first Philippine Commission, also known as the Schurman Commission, started to receive reports as to the vast tracts of lands considered to be private. However, they were more interested in the extent of land rights acquired by the United States and focused its attention to the Philippine archipelago's public domain. Investigations were then conducted, 78 79 80 81 82 83 84 As cited in John Jerico Laudet Balisnomo, Ancestral Domain Ownership and Disposition: Whose Land, Which Lands, 42 ATENEO L. J. 159, l 74 (1997). Owen James Lynch, Jr., Land Rights, Land Laws and Land Usurpation: The Spanish Sea (1565-1898), 63 Phil. L.J. 82, 108 (1988). John Jerico Laudet Balisnomo, Ancestral Domain Ownership and Disposition: Whose Land, Which Lands, 42 ATENEOL. J. 159, 174 (1997). Owen James Lynch, Jr., Land Rights, Land Laws and Land Usurpation: The Spanish Sea (1565-1898), 63 PHIL. L. J. 82, 109 (1988). Id. Owen James Lynch, Jr., The Legal Bases of Philippine Colonial Sovereignty: An Inquiry, 62 PHIL. L. J. 279, 294 (1987) citing G. DEWEY, AUTOBIOGRAPHY OF GEORGE DEWEY, ADMIRAL OF THE NAVY, 222 (1913). Owen James Lynch, Jr., Native Title, Private Right and Tribal Land Law: An Introductory Survey, 57 PHIL. L. J. 268, 276 (1982). nee also Owen James Lynch, Jr., Invisible Peoples and a Hidden Agenda: The Origins of Contemporary Philippine Land Laws (1900-1913), 63 PHIL. L. J. 249 (1988).