## Facts

- Crop-growing Indian villages in the Texcoco area (near Mexico City, by Lake Texcoco) relied on adjacent hillsides to gather wood and make charcoal, a long-used resource base for village households.
- The same hillside area was tied to water flows (springs/streams) important to village farming and daily needs.
- A nearby cattle-ranching estate, Hacienda La Blanca, interfered with village access to the hillside resources that the villages claimed they had long used.
- The villages also complained that the hacienda’s cattle strayed into village cornfields and other cultivated plots, causing crop losses and damage to land needed for subsistence.
- In addition to land and crop harms, the dispute involved abusive demands connected to labor and services: the hacienda sought to compel villagers to perform work related to the hacienda’s operations in ways the villages claimed exceeded what royal law allowed.
- The land at the center of the conflict was part of the Spanish crown’s domain; it was not granted as private property. Local control and administration were placed in the hands of the Alcalde Mayor (a royal magistrate).
- The villages acted through a legal representative and brought the matter before the Royal Audiencia (Royal Audience) of Mexico City, invoking the crown’s special solicitude for Indian communities.
- Proceedings stretched over many years (beginning with a complaint filed on August 7, 1744), with orders to local officials, investigations, and continuing contention between the villages and the hacienda owner.

## Issues

1. Whether the owner of Hacienda La Blanca could lawfully interfere with the Texcoco-area villages’ long-standing use of crown hillsides for wood and charcoal and with associated water needed for village agriculture.
2. Whether the hacienda could allow its cattle to roam into village fields and destroy crops, or instead had a duty to restrain livestock and remedy harms to Indian farming lands.
3. Whether the hacienda could compel Indian villagers to perform labor or services in connection with the hacienda’s livestock and operations beyond what royal law permitted.

## Decision

- The Royal Audiencia intervened in favor of the Indian villages.
- It rejected the hacienda owner’s attempt to treat crown hillside resources as if they were subject to exclusive private control, and it supported the villages’ continued access for wood gathering and charcoal production tied to long usage.
- It ordered restraints to stop or prevent wandering cattle from entering village fields and ruining crops, and required practical measures to protect village agriculture.
- It limited the hacienda owner’s ability to exact labor or services from villagers in coercive form, treating forced service connected to private estate operations as unlawful when inconsistent with royal protections for Indians.
- It used investigative and supervisory measures (through local officials acting under the Audiencia’s direction) to implement relief rather than leaving the villages to local power dynamics.

## Legal Principles

- Crown domain land administered by royal officers could not be converted into exclusive hacienda control simply through local pressure or private use.
- Long-standing community use of common resources (such as hillside wood/charcoal areas) could be recognized and enforced against nearby estates when necessary to sustain village life and farming.
- Hacienda owners could be required to control livestock to prevent trespass and crop destruction, especially where the harmed fields were the basis of subsistence for Indian communities.
- Royal law treated Indian communities as wards entitled to special judicial protection; the Audiencia could intervene directly to secure fair treatment against powerful local landowners.
- Demands for Indian labor connected to a private hacienda were subject to limits: work could not be compelled in ways that functioned as bondage or otherwise exceeded lawful obligations.

## Conclusion

In Coy’s reconstruction of this Audiencia matter, Texcocan villages successfully invoked royal judicial protection against Hacienda La Blanca: the court backed the villages’ access to crown hillside resources and related water, required effective control of roaming cattle to prevent crop loss, and curbed coercive labor exactions inconsistent with royal rules protecting Indian communities.


Texcocan Villages v. Hacienda La Blanca, P.E.B. Coy, Justice for the Indian in Eighteenth-Century Mexico, 12 Am. J. Leg. Hist. 41, 43-46, 49 (1968)