Dissenting Opinion -9- G.R. No. 224469 Contrary to such assertion, moreover, and even assummg that confusion in the law can result in acquittal, there simply is no such confusion in this particular case. Both the Legislature and the Executive have consistently applied a strict approach towards environmental regulation as clearly evident from a historical account of their enactments. Even before the passage of P.D. No. 705, Congress, in 1963, had already imposed the penalty of imprisonment by virtue of R.A. No. 3571 24 on any person who cuts trees in plazas, parks, school premises or m any other public ground without government approval. In 1974 and 1975, then President Ferdinand E. Marcos issued P.D. No. 389 and the subject P.D. No. 705, respectively, similarly penalizing the cutting of timber without permit. ~ '." In 1976, President Marcos again promulgated P.D. No. 953, 25 which amended R.A. No. 3571, prohibiting the unauthorized cutting of trees along public roads, in plazas, parks other than national parks, school premises or in any other public ground or place, or on banks of rivers or creeks, or along roads in land subdivisions or areas therein. The decree also imposed on concerned persons the duty of planting trees in specified places. In 1981, President Marcos next signed Presidential Proclamation No. declaring certain areas as environmentally critical within the scope of the Environmental Impact System under P.D. No. 1586. 27 Said issuances provide that no person may conduct any environmentally critical project (such as logging) 28 in any environmentally critical area (such as those traditionally occupied by cultural communities or tribes )29 without first 2146 26 24 An Act to Prohibit the Cutting, Destroying or Injuring of Planted or Growing Trees, Flowering Plants and Shrubs or Plants of Scenic Value Along Public Roads, in Plazas, Parks, School Premises or in Any Other Public Pleasure Ground. 25 Requiring the Planting of Trees in Certain Places and Penalizing Unauthorized Cutting, Destruction, Damaging and Injuring of Certain Trees, Plants and Vegetation. 26 Proclaiming Certain Areas and Types of Projects as Environmentally Critical and Within the Scope of the Environmental Impact Statement System Established Under Presidential Decree No. 1586. 27 Establishing an Environmental Impact Statement System, Including Other Environmental Management Related Measures andfor Other Purposes (1978). 28 Presidential Proclamation No. 2146 provides: NOW, THEREFORE, I, FERDINANDE. MARCOS, President of the Philippines, by virtue of the powers vested in me by law, hereby proclaim the following areas and types of projects as environmentally critical and within the scope of the Environmental Impact Statement System; A. Environmentally Critical Projects xxxx II. Resource Extractive Industries a. Major mining and quarrying projects b. Forestry projects 1. Logging x x x x (Emphasis ours) 29 Presidential Proclamantion No. 2146 provides: B. Environmentally Critical Areas xx xx (Emphasis ours)