with the issue: whether ancestral domain should be recognized as a legal category in Philippine jurisprudence. Let us begin where it began. The Novisima Recopilacion de Leyes de las Indias started it all. The Spanish Crown put it thus: We having acquired full sovereignty over the Indies, and all lands, territories, and possessions not heretofore ceded away by our royal predecessors, or by us, or in our name, still pertaining to the royal crown and patrimony, it is our will that lands which are held without proper and true deeds of grant be restored to us as they belong to us, in order that after reserving before all what to us or to our viceroys, audiencias, and governors may seem necessary for public squares, ways, pastures, and commons in those places which are peopled, taking into consideration not only their present condition, but also their future and their probable increase, and after distributing to the natives what may be necessary for tillage and pasturage, confirming them in what they now have and giving them more if necessary, all the rest of said lands may remain free and unencumbered for us to dispose of as we may wish. Thus, was asserted the Regalian doctrine. The Spanish King claimed ownership of everything of value in the Indies or colonies thereby stripping natives of their ancestral rights to land. Philippine courts, all the way to the Supreme Court even after the arrival of the Americans, followed the regalia doctrine. Then came Carino vs. Insular Government, a decision penned by Justice Holmes, reversing a decision that had gone all the way to the Philippine Supreme Court. The case involved the claim of a native Ibaloi to ownership antedating colonial times. Whereupon, Justice Holmes ruled in favor of Carino and ordered the registration of the 148 hectares in Baguio in his name. Justice Holmes recognized that he had native title to the land. Can ancestral domain and regalia doctrine stand together?