Dissenting Opinion G.R. No. 224469 mentions of the rights of IPs to claim ownership over areas traditionally and actually occupied by them, to manage and conserve natural resources within the ancestral domains, the right to cultural integrity, or such other rights which every indigenous person should enjoy under the law, there is no mention of any exemption from the licensing requirement as far as the cutting, gathering, collecting, or removing of timber or other forest products is concerned. This Court cannot simply expand the implications of the provisions of IPRA to carve out an exception in favor of indigenous people, when such has not been clearly established to be the intent of the legislature. To do so would run counter to the well-established rule of strict interpretation against exceptions. In Samson v. CA, 5 we ruled that "under the rules of statutory construction, exceptions, as a general rqle, should be strictly, but reasonably construed; they extend only so far as their language fairly warrants, and all doubts should be resolved in favor of the general provisions rather than the exception. Where a general rule is established by statute with exceptions, the court will not curtail the former nor add to the latter by implication." 6 Notably, the IPRA provides an exemption from taxes in favor of ancestral domains owned by indigenous people, to wit: SEC. 60. Exemption from Taxes. - All lands certified to be ancestral domains shall be exempt from real property taxes, special levies, and other forms of exaction except such portion of the ancestral domains as are actually used for large-scale agriculture, commercial forest plantation and residential purposes or upon titling by private persons: Provided, That all exactions shall be used to facilitate the development and improvement of the ancestral domains. Had it been the intent of the legislature to consider the IPRA as an additional authority for indigenous people to cut, gather, collect, remove timber or other forest products within the ancestral domain as an exception to the penal provisions of the Revised Forestry Code, it would have simply expressed so, similar to the clear import to exempt ancestral domains from real property taxes and other forms of state exaction. The fact that no such import was provided under the IPRA is a testament to the proposition that the IPRA was never intended as an exception to the requirement of a permit, license, agreement, or such other authority as may be applicable. I maintain my submission that the IPs do not possess the right to cut forest products free from state regulation. There is no indication that they are excluded from the coverage of PD No. 705. This can be gleaned from a scrutiny of both the literal text and the legislative intent behind PD No. 705, IPRA, and other pertinent regulations. 5 6 230 Phil. 59 (1986). Id. at 64, citing Francisco, Statutory Construction, p. 304, citing 69 CJ., Section 643, pp. 1092-1093

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