Separate Concurring Opinion 7 G.R. No. 224469 Further, it must be noted that the original iteration of Section 77 (then Section 68 of Presidential Decree No. 705 [1975]) was passed under the 1973 Constitution and specifically described "authority" as being "under a license agreement, lease, license or permit. " 26 However, soon after the enactment of the 1987 Constitution or in July 1987, then President Corazon Aquino issued Executive Order No. 277 (EO 277) amending Section 77, which, among others, removed the above-mentioned descriptor, hence, leaving the phrase "without any authority," generally-worded. To my mind, the amendment of Section 77 may be read in light of the new legal regime which gives significant emphasis on the State's protection of our IPs' rights, which includes the preservation of their cultural identity. Given that there was no explanation in EO 277 as to the "authority" required, it may then be reasonably argued that the amendment accommodates the legitimate exercise of IPs' rights within their ahcestral domains. In this relation, the esteemed Chief Justice Diosdado M. Peralta has argued that the "authority" required under Section 77 must be understood as still requiring licenses issued by the DENR because of the provision's heading to wit: "Cutting, Gathering and/or collecting Timber or Other Forest Products Without License." A rule, however, in statutory construction, is that headings may be consulted in aid of interpretation, but "inferences drawn from [them] are entitled to very little weight." 27 Further, it must be borne in mind that Section 77 punishes two separate offenses. In Revaldo v. People: 28 There are two distinct and separate offenses punished under Section 68 of the Forestry Code, to wit: (1) Cutting, gathering, collecting[,] and removing timber or other forest products from any' forest land, or timber from alienable or disposable public land, or from private land without any authority; and (2) Possession of timber or other forest products without the legal documents required under existing forest laws and regulations. 29 Based on the provision itself, the first offense of cutting, gathering, collecting, removing timber or other forest products from any fore st land, or timber from alienable or disposable public land, or from private land is qualified by the general phrase "without any authority," whereas the second offense of possessing timber or other forest products is qualified by 26 27 28 29 The relevant portion of the provision states: SEC. 68. Cutting, Gathering and/or Collecting Timber or Other Products without License. - Any person who shall cut, gather, collect, or remove timber or other forest products from any forest land, or timber from alienable and disposable public lands, or from private lands, without any authority under a license agreement, lease, license or permit, shall be guilty of qualified theft as defined and punished under Articles 309 and 310 of the Revised Penal Code." (Emphasis and underscoring supplied) Kare v. Platon, 56 Phil. 248, 250 (1931), citing Black's Interpretation of Laws. 603 Phil. 332 (2009). Id. at 342.,

Select target paragraph3