Decision 14 G.R. No. 224469 forests inclusive of logged-over areas, commercial forests, and established plantations of the forest trees and trees of economic values. 54 As outlined, Section 77 requires prior authority for any of the acts of cutting, gathering, collecting, removing timber or other forest products even from those lands possessed by IPs falling within the ambit of the statute's definition of private lands. Therefore, the language of Section 77 incriminates petitioners as they cut, gathered, collected, and removed timb'er from a dita tree from the land which they have called their own since time immemorial, which could either be a forest land, or an alienable or disposable public land, or a private land, as defined under PD 705, as amended, without the requisite authority pursuant to PD 705's licensing regime. Justice Caguioa firmly opines, however, that ancestral domains and lands are outside the ambit of Section 77 as these are neither forest land, alienable or disposable public land, nor private land. He is correct that ancestral domains and lands are unique, different, and a class of their own. They have been referred to repeatedly as sui generis property, which sets into motion the construct or paradigm for determining the existence, nature, and consequences of IP rights. 55 Nonetheless, the text of Section 77, as amended is very clear. It does not exempt from its coverage ancestral domains and lands. Too, as Chief Justice Peralta aptly points out, the term "private land," which Section 77 expressly covers, includes lands possessed by "national minorities" such as their sacred and communal grounds. This term should mean no other than what we sensitively and correctly call today as the IPs' ancestral domains and lands. To be sure, Section 77's reference to forest lands and even alienable and disposable public lands could have also encompassed ancestral domains and lands. This is because laws were subsequently passed converting some of the lands through the open, continuous, exclusive, and notorious occupation and cultivation of IPs (then stereotypically referred to as members of the national cultural communities) by themselves or through their ancestors into alienable and disposable lands of the public domain. 56 Three more things. First, Section 77 of PD 705 had been amended a number of times when IP rights were burgeoning as an affirmative action component - in 54 Revised Forestry Code of the Philippines, Presidential Decree No. 705, May 19, 1975. John Borrows and Leonard Rotman, The Sui Generis Nature of Aboriginal Rights: Does it Make a Difference, 1997 36-1 Alberta Law Review 9, 1997 CanLIIDocs 142, <http://www.canlii.org/t/skv8>, retrieved on 2020-09-13. 56 E.g. PD 410 (1974). 55