Separate Opinion 6 G.R. No. 224469 I submit that ancestral domains are distinct from public or private lands, and any cutting of timber or forest product therein was not contemplated by Sec. 77 of P .D. 705. Sec. 77 cannot be read in isolation. Its interpretation should not only be construed strictly against the State and in favor of the accused, but it must consider changes brought about by the 1987 Constitution, its recognition of ancestral domains, and the enactment of the IPRA. "Forest land," 12 as used in P.D. 705, includes three sub-categories: (1) public forests, (2) permanent forests or forest reserves, and (3) forest reservations, which are defined in the statute itself: SECTION 3. Definitions. a) Public forest is the mass oflands of the public domain which has not been the subject of the present system of classification for the determination of which lands are needed for forest purposes and which are not. b) Permanent forest or forest reserves refers to those lands of the public domain which have been the subject of the present system of classification and declared as not needed for forest purposes. xxxx g) Forest reservations refer to forest lands which have been reserved by the President of the Philippines for any specific purpose or purposes. (Underscoring supplied) From these definitions, it is clear that all subcategories of "forest land" are classified as lands of the public domain. 13 Similarly, and as the name suggests, "alienable or disposable public land" 14 also forms part of the public domain. On the other hand, while the term "private land" is not expressly defined in P.D. 705, it is indirectly referred to in Sec. 3(mm), which defines a "private right" as "titled rights of ownership under existing laws, and in the case of national minority to rights of possession existing at the time a license is granted under this Code, which possession may include places of abode and worship, burial grounds, and old clearings, but exclude productive forest inclusive oflogged-over areas, commercial fores-ts and established plantations of the forest trees and trees of economic values." 15 12 13 14 15 P.D. 705, Sec. 3(d). Section 5 of PD 705 affirms this view: "[t]he Bureau [of Forest Development] shall have jurisdiction and authority over all forest land, grazing lands, and all forest reservations including watershed reservations presently administered by other government agencies or instrumentalities." Section 3(c) defines this as "those lands of the public domain which have been the subject of the present system of classification and declared as not needed for forest purposes xx x." P.D. 705, Sec. 3(mm). (Underscoring supplied)