Decision 15 G.R. No. 224469 1987 (EO 277) and then again in 1991 (RA 7161), but never did the authorities change the explicit coverage of the text of Section 77. There was not even an attempt to clarify that ancestral domains. and lands are beyond Section 77 's contemplation, which the authorities could have easily done so. Second, Section 77 was the product of a less-than enlightened age. The era of PD 705 even as amended did not politely call IP lands and communities the IPs' ancestral domains or ancestral lands but tribal grounds or archaeological areas of, or lands occupied and cultivated by, members of the national cultural communities, or public or communal forests. Section 77 was born and nurtured at a time when IPs were referred to as "national minorities" and the enlightened path then was to achieve their redemption through assimilation into the cultural bourgeoisie of the majority. Justice Leonen's Ha Datu Tawahig v. Lapinid5 7 eloquently narrates this sorry stage in our)eg~l history. So does Justice Lopez whose citations refer to our case law when we still called IPs cultural minorities whose status as such is derisively and condescendingly seen as a mitigating circumstance, or the IPs of the Cordilleras as uncivilized Igorots whose alleged backwardness was patronizingly used to lessen the criminal punishment meted. As observed by Justice Kapunan in Cruz v. Secretary of Natural Resources, 58 "Philippine legal history, however, has not been kind to the indigenous peoples, characterized them as 'uncivilized,' 'backward people,' with 'barbarous practices' and 'a low order of intelligence'." This was the construct that permeated either the original or amended iterations of Section 77. This construct rendered it unlikely, to say the least, the exclusion from criminalization of the IPs or ICCs' cultural and customary practices within their ancestral domains and lands. This context · means that Section 77 could not have intended to exclude as its language does not exclude ancestral domains and lands. The rise of aboriginal or IP law and jurisprudence has not come about smoothly· or even peacefully. This was because of the need to correspond to traditional legal conceptions of property rights to receive the law's protection. 59 Indeed, prior to the IPRA, ancestral domains and lands were conceived in this manner: It seems to be common ground that the ownership of the lands was "tribal" or "communal," but what precisely that means remains to be ascertained. In any case it was necessary that the argument should go the length of showing that the rights, whatever they exactly were, belonged to the category of rights of private property. 60 57 G.R. No. 221139, March 20, 2019. Supra note 31 at 1025. 59 John Bon-ows and Lc,x1ard Rotman, supra note 55. 60 Re Southern Rhodesia, [1919) A.C. 211 (P.C.). 58