FACTS: PICOP fled with the Department of Environment and Natural Resources

(DENR) an application to have its Timer !icense "#reement (T!") No$ %& converted
into an Inte#rated 'orest (ana#ement "#reement (I'(")$
ISSUE:
RULING: in interpretin# the term )held under claim of ownership*) the +upreme Court
could not have meant to include claims that had ,ust een fled and not -et
reco#ni.ed under the provisions of DENR "dministrative Order No$ / +eries of 011&*
nor to an- other communit- 2 ancestral domain pro#ram prior to R$"$ 3&40$