Separate Opinion 19 G.R. No. 224469 omitted intentionally);,42 it can be logically concluded that the limitation on the authority to those issued only by the DENR has been intentionally removed. Considering the foregoing, I am of the view that the "authority" contemplated in P.D. 705, as amended, should no longer be limited to those granted by the DENR. Rather, such authority may also be found in other sources, such as the IPRA. 43 To have a strict interpretation of the term "authority" under Sec. 77 of P.D. 705 despite the clear evolution of its text would amount to construing a penal law strictly against the accused, which cannot be countenanced. To stress, [o]nly those persons, offenses, and penalties, clearly included, beyond any reasonable doubt, will be considered within the statute's operation. They must come clearly within both the spirit and the letter of the statute, and where there is any reasonable doubt, it must be resolved in favor of the person accused of violating the statute; that is, all questions in doubt will be resolved in favor of those from whom the penalty is sought. 44 More importantly, to construe the word "authority" in P.D. 705, Sec. 77 as excluding the rights ofICCs/IPs already recognized in the IPRA would unduly undermine both the text and the purpose of this novel piece of legislation and significantly narrow down the rights recognized therein. The varying positions in the case show reasonable doubt which calls for petitioners' acquittal The discussion above lays down my position that petitioners cannot be held liable for violating P.D. 705. Nevertheless, even if the premises I have laid down would be rejected by the Court, I maintain that petitioners in this case should be acquitted. · Contrary to the assertions I have put forth, Chief Justice Peralta dissents and puts the present issues in a different perspective, mainly arguing that the ancestral domains of the indigenous peoples were never carved out from the application of the country's forestry laws, whether by the IPRA or by P.D. 705, 45 and that ancestral domains are not exempted from the regulations in place that pertain to forest use. He adds that the IPRA and P.D. 705 are not pitted against each other, as they cover applications, and complement rather 42 43 44 45 Association of Non-Profit Clubs, Inc. v. Bureau of Internal Revenue, G.R. No. 228539, June 26, 2019, accessed at <https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/65316>. This should not be taken to mean that mere ownership, especially as understood in civil law, already constitutes the "authority" required by Sec. 77, P.D. 705. As discussed, the ownership exercised by the IPs over their ancestral domains is different from the civil law understanding of ownership. People v. Garcia, 85 Phil. 651, 686 (1950). Chief Justice Peralta's Dissenting Opinion, pp. 22-23.