Separate Concurring Opinion 20 G.R. No. 224469 The Torrens system registers and guarantees the legal rights of private land owners. The system was devised during the 1830s by Sir Robert Torrens who had served as commissioner of customs in South Austria before becoming a land registrar of deeds .... The Torrens system promotes the use of land as a marketable commodity. Unlike customary systems, a Torrens title holder need have no relation to the land other than what is stated in the Torrens document. A Torrens title holder is also generally free to convey his or her rights to anyone, regardless of whether or not they belong to the community where the land is located or whether they intend to use the land or leave it idle. 100 Subsequently, Act No. 926, otherwise known as the Public Land Act, was passed. It provided for the various modes as to how public lands can be alienated either through a homestead application, sale, lease, issuance of free patents to native settlers, creation of town sites, or for perfection of titles and Spanish grants. In this regard, the Public Land Act recognized the natives' rights over land that they have continuously occupied and cultivated, either by themselves or through their ancestors: SECTION 32. Any native of the Philippine Islands now as occupant and cultivator of unreserved, unappropriated agricultural public land, as defined by the Act of Congress of July first, nineteen hundred and two, who has continuously occupied and cultivated such land, either by himself or through his ancestors, since August first, eighteen hundred and ninety; or who prior to August first, eighteen hundred and ninety eighty continuously occupied and cultivated such land for three years immediately prior to said date, and who has been continuously since July fourth, nineteen hundred and two, until the date of the taking effect of this Act, an occupier and cultivator of such land, shall be entitled to have a patent issued to him without compensation for such tract of land, not exceeding sixteen hectares, as hereinafter in this chapter provided. In 1919, Act No. 2874 101 superseded Act No. 926. The second Public Land Act "was more comprehensive in scope but limited the exploitation of agricultural lands to Filipinos and Americans and citizens of other countries which gave Filipinos the same privileges." 102 The Public Land Act was followed by Act No. 1148 or the Forest Act. Prior to its enactment on May 7, 1904, the Organic Law of July 1, 1902 already provided, to some extent, the legal framework and procedure for the allocation of legal rights relating to forest lands and the resources found there. The Organic Law provided that the United States Government shall have the power "to issue licenses to cut, harvest, or collect timber or other 100 101 102 Owen James Lynch, Jr., Invisible Peoples and a Hidden Agenda: The Origins of Contemporary Philippine Land Laws, 63 PHIL. L. J. 249,282 (1988). Republic Act No. 2874, sec. 128 provides: Section 128. Act Numbered Nine hundred and twenty-six known as the "Public Land Act," and all acts and regulations, or parts thereof, inconsistent with the provisions of this Act, are hereby repealed. See J. Puno, Separate Opinion in Cruz v. Secretary of Natural Resources, 400 Phil. 904, 940 (2000) [Per Curiam, En Banc]. /