The structure "Modifier-DE (的)" is employed when the modifier is presumed to be true or given. In other words, the nature of this sentence structure is presuppositional.
For instance, in the sentence 他昨天來的 (tā zuó tiān lái de/ He came yesterday), "He came" is a presupposed action, while "yesterday" is asserted in the sentence. However, in the sentence 他來的 (tā lái de), the presupposed verb modifies a head subordinative. Hence, due to the lack of presupposed action in this sentence, it cannot adopt the "modifier-DE" structure.