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Governor Vélez Cachupin and the Pueblo Grants
The colonial Spanish government is believed to have issued grants to all of the existing New Mexico Pueblos in the period between 1598 and 1821.
Governor Tomas Vélez Cachupín and the Grants to the Pueblos of Zía, Jémez, Santa Ana, and Cochiti
By James Dory-Garduño
The colonial Spanish government is believed to have issued grants to all of the existing New Mexico Pueblos in the period between 1598 and 1821. However, all of the documents in the Santa Fe archives prior to 1680 were destroyed during the Pueblo Revolt. During the period following the revolt to 1821, eighteen grants issued by the Spanish government to the Pueblos are known to have survived. Governor Domingo Jironza Pétris de Cruzate allegedly issued thirteen of these grants in September 1689. But these grants, though confirmed by the United States Congress at the recommendation of the Surveyor General, are considered forgeries.
The remaining five grants include the Sandia Pueblo Grant, Cañada de Santa Clara Grant, Cochiti Pueblo Pasture Grant, Espíritu Santo Grant (Pueblos of Zia, Jémez, and Santa Ana), and Santo Domingo and San Felipe Pasture Grant and are unique in that they represent the surviving documents that were issued by a Spanish governor to a New Mexico Pueblo tribe. Accordingly, they deserve to be the subject of a detailed study that establishes their authenticity and discusses the uniqueness of the claims that they contain. The 1766 grant to the Pueblos of Zía, Jémez, and Santa Ana and the similar 1766 Cochiti grant both contain aboriginal claims for land. Governor Tomás Vélez Cachupín issued these grants based on those claims and, in doing so, demonstrated that the Pueblos were not only entitled to protection of their land but also to recognition of their original title.
Very few grants that the Spanish government issued to the Pueblos of New Mexico exist for several reasons. First, the Santa Fe archives were destroyed in the Pueblo Revolt in 1680. In addition, the Pueblos, if they had copies of any conveyances, likely destroyed them as well, since none has produced a document from before the revolt. In the final years of the revolt and shortly afterward, the Spanish Crown specifically provided that Governors Domingo Jironza Petrís de Cruzate and Diego de Vargas could issue land grants to the Pueblos. However, aside from the so-called “Cruzate grants,” which will be discussed below, none issued to a Pueblo has survived from either governor. In the eighteenth century, Governors Joaquín Codallas y Rabal, Tomás Vélez Cachupín, and Pedro Fermín de Mendinueta issued grants to the Pueblos, and these represent the extant documents.
A second reason for so few physical documents is that Spanish royal decrees called for the recognition of indigenous land holdings as matter of law not necessarily dependant on paper title. Under Spanish law found in the Recopilación de las Leyes de los Reynos de las Indias, the indigenous people were entitled to the lands that they occupied. Book iv, title xii, law xviii, for example, states that the Indians should retain “possession of the full amount of lands belonging to them either singularly or in communities” along with the water rights and irrigation works. As such, the lack of documentation did not deny indigenous people either titles or claims to their villages. This last point partially explains why the Cruzate grants have received little attention despite their problematic nature. Nonetheless, the fact that scholars consider these grants to be forgeries increases the need to scrutinize all existing grants issued to an Indian Pueblo. Certainly, before commenting further about the content of non-Cruzate Pueblo grants, the extant documents in the archives in Santa Fe deserve authentication. In the cases of the testimonio of the 1766 Espíritu Santo Grant and the 1766 Cochiti Pueblo Grant, the first step is to distinguish them from the Cruzate grants.
Questions surrounding the Cruzate grants emerged when the Court of Private Land Claims superseded the Surveyor General. A special agent for the court, William M. Tipton, discovered several inconsistencies with the grants. First, Tipton noted that the author of the documents misspelled Governor Domingo Jironza Pétris de Cruzate’s name, using “Petros” for Pétris. Similarly, Tipton noted that the name of Domingo Jironza Pétris de Cruzate’s secretary was Don Pedro Ortiz Niño de Guevara not “Don Pedro Ladrón de Guitara.” No Pedro Ladrón de Guitara ever existed, at least not under this spelling. Also, Governor Domingo Jironza Pétris de Cruzate’s signature on the grants does not match his known valid signature. Scholars also have noted physical characteristics in the documents that suggest that they were created in the nineteenth century. Compared to earlier Spanish documents, the paper appears lighter in complexion but perceivably inferior in quality. Moreover, the watermarked paper used on all of the grants is typical of that produced between 1839 and 1862. The paper has the watermark, “MARIANO” countermarked by an “M” in script. In 1982, State Archivist Richard Salazar submitted two Cruzate grants to Los Alamos Laboratories, who provided evidence that the ink in the Cruzate grants resembled inks used in the mid-nineteenth century. Some have suggested that the grants are simply poor copies. However, the fact that the signatures for different officials are all in the same hand makes it difficult to deny that someone forged the grants.
Of the remaining five grants to the Pueblos, the Sandia Pueblo grant of 1748 is the only grant that recognizes a Pueblo village. The Cañada de Santa Clara grant of 1763 is in the Spanish Archive of New Mexico. This grant resulted from the original Spanish settlers forfeiting their title after violating provisions of the grant, which restricted it to pasturing uses only. Governor Vélez Cachupín revoked their grant and issued a grant to the Santa Clara Pueblo to protect the village and enhance its agricultural lands. The Santo Domingo and San Felipe grant of 1770 was issued for pasturing purposes. The Court of Private Land Claims confirmed this grant. As in the case of the Cañada de Santa Clara grant, the original documents of the expediente remain in the archives. The original signatures on these grants also help establish their authenticity.
The final two grants are the grazing grant to the Pueblos of Zia, Jémez, and Santa Ana (Ojo del Espíritu Santo grant) and the grazing grant to the Pueblo of Cochiti. The Pueblos petitioned for grazing lands, stating that they had considered the requested land as theirs “from their foundation.” These are the only existing New Mexico Pueblo grants that make this claim. Both were granted by Governor Vélez Cachupín in 1766. The Ojo del Espíritu Santo grant to the Pueblos of Zia, Jemez, and Santa Ana in the archives is the testimonio (certified copy) of the original documents. When a grant was issued, the originals were deposited in the archives and testimonios were given to the grantees. The alcalde mayor making the testimonio usually signed the copy but not always. In the case of the testimonio of the Ojo del Espíritu Santo grant, the document is not signed. A partial transcription and translation of the Cochiti Pueblo Pasture grant is found in the records of the Court of Private Land Claims. The claim in the petition is phrased in the exact language as the Ojo del Espíritu Santo grant. Both grants, however, pose problems to the researcher, since neither contains the actual signatures of the officials involved. Often the signatures of the officials, as seen in the Cruzate grants, greatly contribute to establishing the authenticity of the document.
In an effort to authenticate the Ojo del Espíritu Santo grant, the author examined, physically and visually, the texture of the paper, its watermarks, its size, and the ink. The objective was to establish that the grant documents are consistent with other eighteenth- and early-nineteenth-century documents—distinguishing it from the Cruzate grants from the same time. The Espíritu Santo grant consists of two pieces of paper bound together in book form by a single piece of thread. The document measures 214.3 mm by 311.15 mm. The paper has chain-lines every 28.3 mm. This is consistent with paper manufactured before 1800. At some point, each page of the grant was folded three times, creating four rectangular sections. The grant is soiled mostly on the back of the two pages as well as where the folds meet in the gutter. The thread that binds the two pages is missing at the top quarter. There also appears to be a piece of thread that bound the two pages shut or served to attach something to the document. The ink appears consistent throughout the document. The writing fills the first three pages and about one-third of page four. Overall, the paper is in fair to good condition and appears to have been fairly well manufactured. However, the paper is coming apart where it was folded.
The watermark on the first page of the 1766 Espíritu Santo grant is a floral design with the name “COSTA” below it. The second sheet has writing on page three and on one third of the top of page four. Here, a watermark of a bull is visible with the name “NOTARO” below it. The bull is facing toward the gutter or inner edge of the paper with its front legs raised. Mexico’s Archivo General de la Nación has at least thirty-six examples of bulls from the second half of the eighteenth century. Seven of these are strikingly similar to the bull on the Ojo grant—all with dates from 1778-1790. Mexico’s archive also has documents produced by the paper maker, Costa, from the 1780s. The paper utilized in the testimonio of the Espíritu Santo grant thus is not only consistent with paper from this era, but it has watermarks known to have been in New Spain in the 1770s and 1780s. This provides strong evidence that the testimonio is an authentic colonial document, created in the decades following the original grant.
As for the Cochiti claim, while the original documents have not been found, one could make a tentative case for its authenticity based on the transcription in the archives. First, the language in the petition is similar and nearly identical in places to that in the Espíritu Santo grant, and both were drafted by Felipe Tafoya. Phrases such as “como es constante” and “toda forma de Dro.” are found in both documents as are other phrases. Admittedly, these are the formulaic phrases you would expect to find in a petition for land, but Felipe Tafoya used these exact phrases while others stated them in slightly different ways. Secondly, the Cochiti transcription has similar abbreviations. For example, the first ten abbreviations—G’ral (general), Phe (Phelipe), Dro (Derecho), and so on—in the Cochiti grant are all found in the opening lines of the Espíritu Santo grant. These similarities are what you would expect to find in petitions written by an experienced legal representative, who would not formulate similar claims in different ways. While more analysis of the text is needed, the preliminary evidence suggests that an authentic testimonio served as the basis for the existing transcription.
If we accept that these documents represent authentic conveyances from the Spanish government, we can further examine their contents. The most significant element is the claim for lands that the Pueblos considered theirs “from their foundation.” This implies that they had continuous control or exercised sovereignty over the land requested. Essentially, this is an aboriginal claim. Moreover, Felipe Tafoya, a veteran in legal matters, probably phrased the claim in the petitions in the most effective way. In doing so, he would have appealed to (or applied) the laws relating to indigenous settlements found in the Recopilación de las Leyes de los Reynos de las Indias. The Recopilación, a compilation of laws issued by various Spanish monarchs, superseded all other laws in the Spanish Empire. Governor Vélez Cachupín is considered to have had a commanding knowledge of these laws and had cited the Recopilación in previous grants. He acknowledged the claims in each case and issued both grants in 1766.
The governor knew that if the claim by the Pueblos was valid, they were entitled to the grant. For instance, certain laws stated that indigenous populations were entitled to the lands that they possessed and that these lands could not be taken away. They were also entitled to lands that they had held before the arrival of the Europeans. Nothing in the record indicates that other Pueblos or settlers contested or questioned the claim. This is significant since some of the witnesses were relatives of the grantees of the Nuestra Señora de la Luz grant, located south of the valley of the Espíritu Santo. Part of the process of the act of possession was to hear from adverse parties or those that contested the proposed boundaries. The settlers who received the Nuestra Señora de la Luz grant are specifically mentioned in the grant but no protest is recorded. These settlers, however, contested the boundaries on several surrounding grants. That they did not dispute the boundaries on this claim is notable. Perhaps they acknowledged the claim as legitimate and refrained from angering the governor. Perhaps they knew that a claim against indigenous lands would certainly go against them. By recognizing the claim of the three Pueblos, as he similarly did months earlier in the Cochiti Pueblo grant, Governor Vélez settled who should have title to the land. The granting decree gives the three Pueblos “royal possession” of the valley. Moreover, the grant lacks any terms of duration or any condition of use needed to perfect the title as other Spanish grants do. The only condition is the clause that allows for horses of the royal garrison to graze in the valley if needed.
The testimonio of the 1766 Ojo del Espíritu Santo survives on paper that was known to have been available in the decades following the issuance of the original grant. The watermarks confirm this in that each page has the name of a papermaker and watermark that are found in Mexico’s archives. These watermarks are known to have been in use in the 1770s and 1780s. The chain-lines and texture of the paper also are consistent with what was available at the time. The proper alcalde drafted the document as well. From this evidence, the testimonio of the Espíritu Santo appears to be an authentic Spanish colonial document. With less certainty, we can say that the Cochiti grant is probably authentic in that the vocabulary, phrasing, and abbreviations so closely mirror the Espíritu Santo grant. Only further study and the discovery of the original testimonio or expediente will allow us to make a better evaluation. In the meantime, we may conclude that in 1766 Governor Vélez Cachupín issued grants to the Pueblos of Zía, Jémez, and Santa Ana and most probably Cochiti Pueblo. He acknowledged their aboriginal claims. In doing so, he made good on the Crown’s desire to recognize the claims of indigenous peoples to the lands that they considered theirs “from their foundation.”
 For the revolt (1680–1692), see Andrew L. Knaut, The Pueblo Revolt of 1680: Conquest and Resistance in Seventeenth-Century New Mexico (Norman: University of Oklahoma Press, 1995); for a wider discussion of the causes of the revolt, see David J. Weber, ed., What Caused the Pueblo Revolt of 1680? (New York: Saint Martin’s Press, 1999).
 We also have documentation from Governor Alberto Maynez confirming the Taos Pueblo’s village boundaries, but this is not the original grant that was issued to the Pueblo. See Correspondence of Governor Alberto Maynez, Santa Fe, 18 April 1816, Records of the United States Surveyor General, New Mexico State Records Center and Archives, Santa Fe, NM (hereinafter SG), Report I; in addition to the grants conveyed to the Pueblos, Governor Tomás Vélez Cachupín issued a grant to a community of Genízaro Indians, founding the settlement of Santo Tomás de Abiquiu. See Abiquiqu Grant, Santa Fe, 10 May 1754, SG, 140; Governor Vélez Cachupín also resettled the Sumas Nation near El Paso at San Lorenzo de Real in 1765. See Spanish Archives of New Mexico, Series I, New Mexico State Records Center and Archives, Santa Fe, NM (hereinafter SANM I), 1350.
There also were numerous land purchases by various Pueblos at various times from various persons, but they are beyond the scope of this study.
 The Pueblos that submitted or possessed Cruzate grants are Jémez, Ácoma, San Juan, Picuris, San Felipe, Sandia (not submitted), Cochiti, Pecos, Santo Domingo, Zía, Laguna, San Cristóbal, and Zuñi. The grants are in the Records of the Surveyor General, New Mexico State Archives and Records Center, Santa Fe, NM, Reports A-G, O, S, U, V. Reports F and V have translations only. A copy of the Sandia Cruzate grant is in the Land Grant Miscellaneous Files, New Mexico State Archives and Records Center, Santa Fe, NM, Box 2, file 18. The Pueblos that did not submit a Cruzate grant are Taos, Santa Clara, Nambé, Tesuque, San Ildefonso, Pojoaque, Santa Ana, and Isleta. The Surveyor General interviewed these Pueblos in 1854; they generally claimed that they had had a Spanish grant at one time but that it had been lost or destroyed.
 The principal reasons that they are considered forgeries is that the signatures are all in the same hand and that Domingo Jironza Petrís de Cruzate’s signature does not match his known authentic signature; that the paper that the grants utilize is from the early to mid-eighteen hundreds; and that the grants contain multiple anachronisms. See Sandra Mathews-Lamb, “The ‘Nineteenth-Century Cruzate Grants’: Pueblos, Peddlers, and the Great Confidence Scam?” (PhD diss., University of New Mexico, 1998).
 Those grants are: 1) Sandia Pueblo Grant (possibly a testimonio), Santa Fe, 14 May 1748, in Spanish Archives of New Mexico, Vol. 2, 220-225, edited by Ralph Emerson Twitchell. (Cedar Rapids, IA: The Torch Press, 1914); the University of New Mexico School of Law also has a copy of the original documents with a translation by Myra Ellen Jenkins on their library website. See https://repository.unm.edu/dspace/bitstream/1928/3058/1/Spanish%20Archives%20of%20New%20Mexico%20I%20%23848.pdf (Accessed 24 June 2008); 2) Cañada de Santa Clara Grant, Santa Fe, 17 July 1763, SG, 138; 3) Cochiti Pueblo Pasture Grant (possibly a testimonio), Santa Fe, 17 August 1766, Court of Private Land Claims, New Mexico State Records Center and Archives, Santa Fe, NM (hereinafter PLC), 172; 4) Testimonio of the Ojo del Espíritu Santo Grant (Pueblos of Zía, Jémez, and Santa Ana), Santa Fe, 28 September 1766, SG, Report TT; and 5) Santo Domingo and San Felipe Pasture Grant, Santa Fe, 10 September 1770, SRG, 142.
 The nineteen existing New Mexico Pueblos are: Ácoma, Cochiti, Isleta, Jémez, Laguna, Nambé, Picuris, Pojoaque, Sandia, San Felipe, San Ildefonso, San Juan, Santa Ana, Santa Clara, Santo Domingo, Taos, Tesuque, Zia, and Zuñi. For a general survey of the Pueblos, see Joe Sando, Pueblo Nations: Eight Centuries of Pueblo Indian History (Santa Fe: Clear Light Publishers, 1992).
 For a discussion of the possibility of grants pre-dating the Pueblo Revolt, see Herbert O. Brayer, Pueblo Indian Land Grants of the “Rio Abajo,” New Mexico (Albuquerque: University of New Mexico Press, 1939). Many of the Pueblos testified to the Surveyor General in 1856 that they had had a Spanish grant at one point in time, but that the grant had been lost.
 Carlos II to Jironza Pétris de Cruzate, 1684, Spanish Archives of New Mexico, Series I, 1338 (here after SANM I).
Of the grants that Diego de Vargas issued, the most prominent was the founding of the villa or town of Santa Cruz de la Cañada. See Santa Cruz de la Cañada Grant, Santa Fe, 1 July 1695, PLC, 181.
 See supra n. 5.
 Carlos II, et al. Recopilación de las Leyes de los Reynos de las Indias. 4 vols. (Madrid: Julián de Paredes, 1681. Facsimile reprint. Madrid: Ediciones Cultura Hispánica, 1973) (hereinafter Recopilación). The Recopilación was a compilation of the laws issued by the Crown and its viceroys concerning Spanish administration of the New World. Parts of book iv and all of book vi had provisions specifically aimed at protecting the native inhabitants and their property.
 Recopilación, book iv, title xii, law xviii.
 For the court’s history, see Richard Wells Bradfute, The Court of Private Land Claims: The Adjudication of Spanish and Mexican Land Grant Titles, 1891-1904 (Albuquerque: University of New Mexico Press, 1975).
 Brayer, Pueblo Indian Land Grants of the “Rio Abajo,” 14.
 Laguna Pueblo “Cruzate Grant” (spurious) Nuestra Señora de Guadalupe del Paso del Río del Norte, 25 September 1689, SG, Report S, 1. This error is found in all of the Cruzate grants.
 Sandra Mathews-Lamb, “Designing and Mischievous Individuals”: The Cruzate Grants and the Office of the Surveyor General, New Mexico Historical Review 71 (October 1996): 341.
 Brayer, Pueblo Indian Land Grants of the “Rio Abajo,” 14.
 Mathews-Lamb, “Designing and Mischievous Individuals,” 341-359; also, see Mathews-Lamb, “The 19th-Century Cruzate Grants.”
 The author made this observation by visually comparing the 1766 and 1815 Ojo del Espíritu Santo grants and the Laguna Pueblo Cruzate Grant, Spring 2008.
 Mathews-Lamb, “The 19th-Century Cruzate Grants,” xiv, 96-98.
 Ibid., 96–7. Mathews-Lamb states that the grants used sheets that had a “MARIANO” block-lettered watermark. The author examined the Laguna grant and found that the watermark was a script in the middle crease, where the paper had deteriorated considerably. This presumably was the countermark to the “MARIANO” watermark, but the second leaf was so badly deteriorated in the center that the watermark could not be viewed.
 Ibid., 186. Los Alamos Laboratories examined the Zia and Picuris Cruzate Grants and an 1856 translation of the Picuris grant along with various documents from 1689 to 1827. The laboratory analyzed the amounts of potassium, calcium, iron, zinc, and lead. The results varied for the different documents. However, the inks in the signatures of the Cruzate grants were compared with the 1856 translation of the Picuris grant. The element patterns were essentially the same.
The author attempted to obtain a copy of the results of the study from the New Mexico State Records Center and Archives, Santa Fe, New Mexico in Spring 2008, but it was unavailable.
 For a discussion of this theory, see Mathews-Lamb, “The 19th-Century Cruzate Grants,” 94.
 Sandia Pueblo Grant, in Spanish Archives of New Mexico, vol. 2, 220-225.
 Cañada de Santa Clara Grant, SG, 138.
 Santo Domingo and San Felipe Pasture Grant, SG, 142.
 Incidentally, these two were the only Pueblo grants not confirmed by the Court of Private Land Claims.
 Cochiti Pueblo Pasture Grant, PLC, 172.
 Compare the Testimonio of the Ojo del Espíritu Santo Grant, SG, TT with the Cochiti Pueblo Pasture Grant, PLC, 172.
 The author also was able to identify alcalde mayor Antonio de Armenta as the drafter of the testimonio of the Ojo del Espíritu Santo in a previous study.
 Eight and seven-sixteenths of an inch by twelve and one-quarter inch.
 Chain-lines are the vertical watermarks from the screen mesh that was used to make the paper.
 Raymond Clemens and Timothy Graham, Introduction to Manuscript Studies (Ithaca, NY: Cornell University Press, 2007), 7.
 Most of the existing land grants from the Spanish period that were collected by the Surveyor General as well as those that were adjudicated by the Court of Private Land Claims are folded in this manner. In contrast, documents that otherwise survive are not folded like this.
 The 1815 Ojo del Espíritu Santo grant was drafted on similar paper. The 1815 grant has chain-lines at the same interval and has the word “DON” as its watermark in the center of the paper. Ojo del Espíritu Santo Grant, Santa Fe, 24 May 1815, SG 44.
The Laguna Pueblo Cruzate Grant of 1689 consists of two sheets of paper, with writing on both sides and is also folded three times. The paper has deteriorated more than that of the 1766 and 1815 grants, suggesting that it was of a lesser quality. The deterioration on the first page has resulted in only a small part of the watermark still in existence, which is not enough to conclusively determine if it is the same as the second page. Laguna Pueblo Cruzate Grant.
 Notaro produced paper that was used in New Spain in the 1770 and 1780s, including a bull watermark. See Sánchez de Bonfil, El Papel del Papel en la Nueva España, 167-205.
 Felipe Tafoya signed his name “Phelipe.”
 Compare the Testimonio of the Ojo del Espíritu Santo Grant, SG, TT with the Cochiti Pueblo Pasture Grant, PLC, 172.
 Testimonio of the Ojo del Espíritu Santo Grant, SG, TT; Cochiti Pueblo Pasture Grant, PLC, 172.
 An aboriginal claim simply means that an indigenous group is laying claim to lands that they possessed and controlled in some manner before or after the arrival of Europeans. For further discussion and the development of this concept in the modern era, see Nell Jessup Newton et al., eds., Cohen’s Handbook of Federal Indian Law, Newark, NJ: LexisNexis, 2005), 969–982. For the acknowledgement that Spain granted title in fee simple to the Pueblos, see ibid., 982.
 E.g., Cañada de Santa Clara Grant, SG, 138.
 The only condition that Governor Vélez Cachupín placed on the Pueblos was that in “urgent cases” the lands granted should be available for the horses of the royal garrison for grazing. With the constant threat of nomadic raiders surrounding the settlements of New Mexico, this seems consistent with the governor’s responsibility of protecting the kingdom.
 Recopilación, book vi. title xii, law, xviii.
 Recopilación, book vi. title xii, law, xviii; book vi. title iii, law, ix.
 Recopilación, book vi. title iii, law, ix.
 See Malcolm Ebright, “Breaking New Ground: A Reappraisal of Governors Vélez Cachupín and Mendinueta and Their Land Grant Policies.” Colonial Latin American Historical Review 5 (1996): 195-233.
 Juan Bautista Montaño was Bernabé Montaño’s brother—the leader of the grantees of the Nuestra Señora de la Luz community grant of 1752.
 This is exactly what happened in the refounding of the Sandia Pueblo in 1748. The settlers on the eastern bank of the Rio Grande stated that the proposed boundaries of the Pueblo would overlap their lands. They subsequently agreed to let the Pueblo use this land for grazing, but the “regular Pueblo league” had to be altered. See Sandia Pueblo Grant in Twitchell, Spanish Archives of New Mexico, 2:222–3.
 Testimonio of the Ojo del Espíritu Santo Grant, SG, TT, 2.
 See Malcolm Ebright, “Breaking New Ground,” 220.
 Ibid., 222.
 Testimonio of the Ojo del Espíritu Santo Grant, SG, TT, 3; Under medieval Castilian law, one took possession of property by entering and occupying it. See Alfonso X, Siete Partidas, trans. Samuel Parsons Scott, ed. Robert I. Burns, S.J., 5 vols. (Philadelphia: University of Pennsylvania Press, 2002), Part. III, title. 30, law vi. One who had possession of the property in question had the presumption of ownership. Ibid. Part. III, title. 30, law xii. The Siete Partidas served to supplement the law where the Recopilación lacked clarity. See Cutter, The Legal Culture of Northern New Spain, 32; Richard E. Greenleaf, “Land and Water in Mexico and New Mexico, 1700-1821,” New Mexico Historical Review 47 (1972): 85-112.
 Testimonio of the Ojo del Espíritu Santo Grant,3.
 See supra n. 34.