62 municipalities in indigenous areas for state reasons precisely as a factor hampering their “recognition and 309 consolidation.” It has also considered that it runs counter to legal certainty of the indigenous peoples’ 310 title deeds. Moreover, in this specific case, the IACHR notes that this measure prevented titling of the Community’s ancestral lands, because, as transpires from the proceedings begun with the INA in January 2001, lot A1 – considered “within the urban perimeter” and containing the 22 manzanas in dispute – was excluded from the title granted. 240. The Commission notes that once these lands had been declared urban, they came under the jurisdiction of the Municipality of Tela and therefore became subject to the legislation on such land. Here, the IACHR points out that, pursuant to the aforementioned article 70 of the Municipalities Law, 311 adopted through Decree No.134-90 of November 19, 1990, “urban communal land real estate in which possession by private individuals was not legalized become fully owned by a municipality whose urban perimeter had been determined when this law came into force,” thereby affecting the Community’s ancestral lands to which no title had been granted. It also notes that the same provision authorized the Municipality to grant full ownership of “urban communal land real estate in the possession of private individuals without full ownership title […] after payment of an amount to be determined by the Municipality […].”This made it possible for outsiders occupying Garífuna land to obtain full ownership titles in return for payments to Municipality. 241. The Community’s property right with respect to land to which it had title was also impaired because, as shown earlier, State authorities granted ownership titles to private persons. As the INA ascertained, by 2001, at least 10 non-Garífuna individuals had full ownership titles in this area. This happened despite the fact that the collective titles of 1993 and 2001 expressly prohibited sales to persons who were not members of the Community, while the title granted in 2001 further required “approval by the Management Board of the Community Council, which approval had to be included in the ownership transfer instrument.” 242. The IACHR considers it a particularly serious matter that State agents, in their attempt to sell Community land, took part in and fostered the creation and maintenance of a “parallel council.” In the IACHR’s view, that constituted grave interference in the political and social organization of the Community which triggered divisions within the Community that were to last until now. It further understands that the pressure exerted on members of the Community to force them to sell ancestral lands, and the actions of State agents – both municipal and Public Registry officials – to achieve such sales, affected the Triunfo de la Cruz Community’s form of succession, in that it contravened the Garífuna people’s collective conception of its land, in which land is a sacred heritage of the Community and should be distributed according to customary law. It added an economic valuation dimension foreign to the Community, thereby 312 affecting its self identity. 243. The IACHR considers it right to include restrictions on the sale of indigenous territory in the title deed in as much as it provides legal certainty, and it also appreciates the existence of a provision in the Property Law establishing that “no authority may issue or register a title in favor of third parties in 309 IACHR, Report on the Situation of Human Rights in Brazil. Doc. OEA/Ser.L/V/II.97, Doc. 29 rev. 1, September 29, 1997, paragraphs 40-43, 83-Recommendation 5. 310 IACHR, Indigenous and Tribal Peoples’ Rights Over Their Ancestral Lands and Natural Resources. Norms and Jurisprudence of the Inter-American Human Rights System. OEA/Ser.L/V/II.Doc.56/09, December 30, 2009, paragraph 91. 311 Law on Municipalities, adopted through Decree No. 134-90 on November 19, 1990 and modified by Decree No. 1252000 on October 6, 2000. Source: Judiciary of Honduras. Electronic Center for Judicial Documentation and Information - CEDIJ. Available at: http://www.poderjudicial.gob.hn/institucional/organizacion/dependencias/cedij/Leyes/Documents/LEY%20DE%20MUNICIPALIDAD ES.pdf.. 312 Thus, Mario Valerio, a former President of the Community Council, stated “for us, splitting the land runs counter to the very existence of our community and all the values that go with it.” Annex 67. Complaint lodged with the Office of the Attorney General in Tela dated February 27, 2003. Annex 56 of the initial petition dated October 27, 2003, received by the IACHR on October 29, 2003.