Dissenting Opinion - 3I - G.R. No. 224469 before it, in U.S. vs. Pascual, a 1908 case, lack of instruction was already held not applicable to crimes of theft or robbery. The Maqui case was decided in 1914, when the state of civilization of the Igorots has not advanced as it had in reaching its present state since recent years, when it certainly can no longer be said of any member of a cultural minority in the country that he is uncivilized or semi-uncivilized. 85 As early as 1981, Macatanda had already recognized the undeniable advancement of IPs insofar as civilization is concerned. A prime example of this is petitioners themselves: indigenes who are Grade IV graduates. It should no longer be reasoned that the unique character of IPs must operate to create a lenient exemption in their favor. As Macatanda instructs, mere membership in a cultural minority and the supposed lack of instruction it entails, does not completely exonerate an accused from criminal liability under penal laws. Be that as it may, Ju~tice Perlas-Bernabe asserts Section 20(c) 86 of the ENIPAS Act of 2018, 87 which amended the NIPAS Act of 1992, to be another statute apart from the IPRA where the State permits IPs to utilize natural resources within their ancestral domains. She then concludes that this provision accurately demonstrates the constitutional and statutory protection of legitimate exercises of IPs' rights in an environmental legislation. The argument, however, fails to take certain circumstances into account. In the first place, the land where the dita tree was cut herein is not covered by the provisions of the ENIP AS Act. The said law provides that a National Integrated Protected Areas System which aims to ensure sustainable use of resources shall apply to all designated protected areas, 88 one of which Mounts Iglit-Baco Natural Park in Occidental and Oriental Mindoro. 89 But while the land subject of the present case is also in the province of Oriental Mindoro, it is not located in any of the municipalities ~ " 85 People v. Macatanda, supra note 83, at 5 IO. (Emphasis ours) Section 20 (c) which provides: Sec. 20. Prohibited Acts. - Except as may be allowed by the nature of their categories and pursuant to rules and regulations governing the same, the following acts are prohibited within protected areas: xxxx (c) Cutting, gathering, removing or collecting timber within the protected area including private lands therein, without the necessary permit, authorization, certification of planted trees or exemption such as for culling exotic species; except, however, when such acts are done in accordance with the duly recognized practices of the IPs/ICCs for subsistence purposes; 87 An Act Declaring Protected Areas and Providing for Their Management, Amending for This Purpose Republic Act No. 7586, Otherwise Known as the "National Integrated Protected Areas System (NIPAS) Act of 1992" and for Other Purposes, approved on June 22, 2018. 88 Section 2 ofR.A. No. 11083 provides: Sec. 2. Declaration of Policy. - xx x "To this end, there is hereby established a National Integrated Protected Areas System (NIPAS), which shall encompass ecologically rich and unique areas and biologically important public lands that are habitats of rare and threatened species of plants and animals, biogeographic zones and related ecosystems, whether terrestrial, wetland or marine, all of which shall be designated as 'protected areas'. ~ 89 See Section 5 ofR.A. No. 11083 for full list of protected areas. 86 - '