Decision 24 G.R. No. 224469 The confusion and the resulting reasonable doubt on whether petitioners were authorized by the State have surfaced from the following circumstances: One. In light of the amendments to Section 77, the lawful authority seems to be probably more expansive now than it previously was. Presently, the authority could be reasonably interpreted as being inclusive of other modes of authority such as the exercise of IP rights. As observed by Senior Associate Justice Perlas-Bernabe: Further, it must be noted that the original iteration of Section 77 (then Section 68 of Presidential Decree No. 705 [1975]) was passed under the 1973 Constitution and specifically described "authority" as being "under a license agreement, lease, license or permit." However, soon after the enactment of the 1987 Constitution or in July 1987, then President Corazon Aquino issued Executive Order No. 277 (EO 277) amending Section 77, which, among others, removed the above-mentioned descriptor, hence, leaving the phrase "without any authority," generally-worded. To my mind, the amendment of Section 77 should be read in light of the new legal regime which gives significant emphasis on the State's protection of our IP's rights, which includes the preservation of their cultural identity. Given that there was no explanation in EO 277 as to the "authority" required, it may then be reasonably argued that the amendment accommodates the legitimate exercise ofIP's rights within their ancestral domains. (Emphasis in the original) The evolution of the penal provision shows that authority has actually become more expansive and inclusive. As presently couched, it no longer qualifies the "authority" required but includes ANY authority. As sharply noted by Senior Associate Justice Perlas-Bernabe, the phrasing of the law has evolved from requiring a "permit from the Director" in 1974 under PD 389, to a mere "license agreement, lease, license or permit" under PDs 705 and 1559 from 1975 to 1987, and to "any authority" from 1987 thereafter. Without any qualifier, the word "authority" is now inclusive of fonns other than permits or licenses from the DENR. This doubt is reasonable as it arose from a principled reading of the amendments to Section 77, and this doubt ought to be construed in petitioners' favor. Justice Caguioa vigorously posits as well that "[c]onsidering the foregoing, I have, from the very beginning, and still am, of the view that the 'authority' contemplated in PD 705, as amended, should no longer be limited to those granted by the DENR. Rather, such authority may also be found in other sources, such as the IPRA." He cogently reasons out: To have a strict interpretation of the term "authority" under Sec. 77 of P.D. 705 despite the clear evolution of its texi would amount to construing a penal law strictly against the accused, which cannot be countenanced. To stress, "[ o]nly those persons, offenses, and penalties, clearly included, beyond any reasonable doubt, will be considered within the statute's operation. They must come clearly within both the spirit and the letter of the statute, and where there is any reasonable doubt, it must be resolved in favor of the person accused of violating the statute; that is, all