the land-use zoning and not the titleholders. If a municipality wishes to purchase five hectares of titled land within a CADT for a garbage dump, IPRA states that the IP group must first consent. The JAO denies the IP group of clearly stated IPRA rights and authority by removing these titled lands from the IP group’s jurisdiction. n The JAO does not include CADCs as under NCIP jurisdiction. Not including DENR-issued CADCs/CALCs as areas under the jurisdiction of NCIP is another major legal flaw of the JAO. IPRA specifically refers to areas covered by the implementation of DENR-DA0 02, 1993 as being government recognized ancestral domains and must be automatically considered as under NCIP jurisdiction. n Certification of Non-Overlap (CNO) regime is discriminatory against NCIP jurisdiction protecting IP land rights. CNOs are required in the JAO from DENR-DAR-LRA for registration of CADT/CALTs issued by NCIP in contested areas. However, no equivalent CNO is required from the NCIP for the registration of titles issued by DENR-DAR-LRA in these same contested areas. n DAR reservations are mistakenly declared as areas “for the common and public welfare and services” which have to be excluded from CADTs. This is illogical and is a contradiction of terms for the JAO to automatically exclude all DAR reservations from ancestral domains based on the clause “except for areas for the common and public welfare and services.” The distribution of land by DAR to individual beneficiaries and the granting of CLOA titles removes land from the public domain to become privately owned land by the CLOA holder. The land is no longer for the common and public welfare and services when it has been distributed as private land. The clause is a legally flawed convenience to prevent the JAO from any possible restraint of DAR jurisdiction. n There is no legal basis for exclusion/segregation of approved surveyplans from ancestral domains. The JAO excludes all approved survey plans from ancestral domains. An approved survey plan is merely a technical instrument to identify the location on the ground of plots of land. It does not convey any type of rights of ownership or control over these land areas and is not subject to IPRA Sec. 56 prior existing rights regime. n The required stamping of CADTs with “subject to IPRA Sec. 56” undermines the purpose of the JAO and the concept of the perfection 24 The Joint Administrative Order No. 01 series of 2012: A Policy Review