10/12/2019 E-Library - Information At Your Fingertips: Printer Friendly [41] Emphasis and underscoring added. [42] Phil Pharmawealth, Inc. v. Pfizer, Inc., 649 Phil. 423, 438 (2010), citing Fabia v. Court of Appeals, 437 Phil. 389, 402-403 (2002). [43] IPRA, Section 38. [44] IPRA, Section 39. [45] IPRA, Section 67. [46] Citing October 9, 1997 Bicameral Conference Meeting on the Disagreeing Provisions of SBN 1728 and 9125. (Emphasis in the original) [47] Emphasis added; underscoring in the original. [48] Subject: Clarifying, Restating and Interfacing the Respective Jurisdictions, Policies, Programs and Projects of the Department of Agrarian Reform (DAR), Department of Environment and Natural Resources (DENR), Land Registration Authority (LRA) and the National Commission on Indigenous Peoples (NCIP) in Order to Address Jurisdictional and Operational Issues Between and Among the Agencies. [49] Republic Act No. 6657. [50] Commonwealth Act No 141, as amended. [51] Act No. 496. [52] Presidential Decree No. 1529. [53] Exhaustion of all remedies provided under customary laws, and the Certification issued by the Council of Elders/Leaders who participated in the attempt to settle the dispute that the same has not been resolved. [54] Estate Nelson Dulay v. Aboitiz Jebsen Maritime Inc., et al., 687 Phil. 153, 162 (2012). [55] Emphasis in the original; underscoring added. [56] Sec. 56. Existing Property Rights Regimes. - Property rights within the ancestral domains already existing and/or vested upon effectivity of this Act, shall be recognized and respected. [57] Cruz v. Secretary of Environment & Natural Resources, 400 Phil. 904, 1080 (2000), Separate Opinion of Justice Santiago M. Kapunan. elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/63044 26/32