Dissenting Opinion - 10 - G.R. No. 224469 securing an Environmental Compliance Certificate issued by the President or his duly authorized representative. 30 In 1987, then President Corazon C. Aquino, circulated E.O. No. 277, which amended P.D. No. 705 and penalized the mere possession of timber without the requisite legal documents. As discussed above, moreover, E.O. No. 277 retained the permit requirement under P.D. No. 705. In 1990, the DENR, in Administrative Order (AO) No. 79, Series of 1990, similarly maintained the authorization requirement on the harvesting, transporting, and sale of firewood, pulpwood or timber planted in private lands in the form of a certificate from the Community Environment and Natural Resources Office (CENRO). 31 In 1992, Congress enacted R.A. No. '7586, 32 otherwise known as the "National Integrated Protected Areas System (NIPAS) Act of 1992," which prohibited the hunting, destroying, disturbing, or mere possession of any plants or animals or products derived from protected areas without a permit from the Management Board. In 1995, then President Fidel V. Ramos executed E.O. No. 263 33 adopting a Community-Based Forest Management to ensure the sustainable development of the country's forestland resources. It stated that 5. Areas which are traditionally occupied by cultural communities or tribes; Section 4 of P.D. No. 1586 provides: Section 4. Presidential Proclamation of Environmentally Critical Areas and Projects. The President of the Philippines may, on his own initiative or upon recommendation of the National Environmental Protection Council, by proclamation declare certain projects, undertakings or areas in the country as environmentally critical. No person, partnership or corporation shall undertake or operate any such declared environmentally critical project or area without first securing an Environmental Compliance Certificate issued by the President or his duly authorized representative. For the proper management of said critical project or area, the President' may~by his proclamation reorganize such government offices, agencies, institutions, corporations or instrumentalities including the re-alignment of government personnel, and their specific functions and responsibilities. 31 In People v. Dator, 398 Phil. 109, 121-122 (2000), the Court held that: "The appellant cannot validly take refuge under the pertinent provision of DENR Administrative Order No. 79, Series of 199025 which prescribes rules on the deregulation of the harvesting, transporting and sale of firewood, pulpwood or timber planted in private lands. Appellant submits that under the said DENR Administrative Order No. 79, no pennit is required in the cutting of planted trees within titled lands except Benguet pine and premium species listed under DENR Administrative Order No. 78, Series of 1987, namely: narra, molave, dao, kamagong, ipil, acacia, akle, apanit, banuyo, batikuling, betis, bolong-eta, kalantas, lanete, lumbayao, sangilo, supa, teak, tindalo and manggis. Concededly, the varieties of lumber for which the appellant is being held liable for illegal possession do not belong to the premium species enumerated under DENR Administrative Order No. 78, Series of 1987. However, under the same DENR administrative order, a certification from the CENRO concerned to the effect that the forest products came from a titled land or tax declared alienable and disposable land must still be secured to accompany the shipment. This the appellant failed to do, thus, he is criminally liable under Section 68 of Presidential Decree No. 705 necessitating prior acquisition of permit and "legal documents as required under existing forest laws and regulations." (Emphasis ours) 32 An Act Providing for the Establishment and Management of National Integrated Protected Areas System, Defining its Scope and Coverage, and for Other Purposes. 33 Adopting Community-Based Forest Management as the National Strategy to Sustainable Development of the Country's Forestlands Resources and Providing Mechanisms for it Implementation. 30 Ensurttthe