Ancestral Lands in the Philippines

Respondents being holders of a mere CALC, their right to possess the subject land is limited to occupation in relation to cultivation. Unlike No. 1,26 Par. 1, Section 1, Article VII of the same DENR DAO, which expressly allows ancestral domain claimants to reside peacefully within the domain, nothing in Section 2 grants ancestral land claimants a similar right, much less the right to build permanent structures on ancestral lands—an act of ownership that pertains to one (1) who has a recognized right by virtue of a Certificate of Ancestral Land Title. (Philippine Economic Zone Authority vs. Carantes)