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	GR No. 161881 2008-07-31	NICASIO I. ALCANTARA v. DEPARTMENT OF ENVIRONMENT AUSTRIA-MARTINEZ, J.
Petitioner further calls for IPRA's application, since "the right to lands of the ancestral domain arose only in view of the IPRA Law and cultural minorities had priorly no right to recover their ancestral lands."[39] Petitioner is utterly mistaken or misinformed. Before IPRA, the right of ICCs/IPs to recover their ancestral land was governed by Presidential Decree (P.D.) No. 410,[40] which declared ancestral lands of national cultural communities as alienable and disposable, and E.O. No. 561,[41] which created the COSLAP. These laws were the bases of the Court's decision in G.R. No. 145838. That the rights of most ICCs/IPs went largely unrecognized despite these laws was not due to the laws' inadequacies, but due to government indifference and the political inertia in their implementation.[42]