33 a) with regard to Anstraun Aman Villagrán Morales, his mother, Matilde Reyna Morales García, and his siblings, Lorena Dianeth, Reyna Dalila and Gerardo Villagrán Morales; b) with regard to Henry Giovanni Contreras, his mother, Ana María Contreras, and his siblings, Mónica Renata Agreda Contreras, Shirley Marlen Agreda Contreras and Osman Ravid Agreda Contreras. The Commission also includes Wilson Ravid Agreda Vásquez, who it indicates is the victim’s son; c) with regard to Julio Roberto Caal Sandoval, his grandmother, Margarita Urbina; d) with regard to Federico Clemente Figueroa Túnchez, his mother, Marta Isabel Túnchez Palencia, his father, Federico Facundo Figueroa, and his siblings, if there are any; and e) with regard to Jovito Josué Juárez Cifuentes, his mother, Noemí Cifuentes, his father, Jorge Juárez, and his siblings, if there are any. The State’s arguments 77. On this point, the State indicated that: a) with regard to pecuniary damage, the judgment on reparations should take into account those who had suffered violations and, when this was not feasible, the direct next of kin. Therefore it recognizes as direct victims: Anstraun Aman Villagrán Morales, Henry Giovanni Contreras, Federico Clemente Figueroa Túnchez, Julio Roberto Caal Sandoval and Jovito Josué Juárez Cifuentes and, consequently, as a result of the violations that they suffered directly, Ana María Contreras, Matilde Reyna Morales García, Rosa Carlota Sandoval, Margarita Urbina, Marta Isabel Túnchez Palencia and Noemí Cifuentes. The State does not recognize that any other person has a right to receive reparations; b) the Commission did not provide hard evidence to prove that those who died had held continuous, stable and permanent employment. The same loss of earnings criterion should not be applied to all those who died, as the Commission has done, without taking into account their real age and hard evidence to demonstrate their working activities. Accordingly, it opposes the Commission’s calculation for this item. Moreover, the Court should accept as proved that the victims and their families did not have a close emotional relationship, so that it cannot be claimed that there was a financial collaboration between them: and c) the calculations should be made on the basis of the concept of ‘life expectancy [...]’, based on the concept of ‘life expectancy at birth’, less the years of life of the victims72, and it is therefore necessary to take into 72 According to the State, information provided by the National Institute of Statistics of Guatemala (INE) should be used; according to this, the life expectancy at birth for the years 1990-1995 was 59.78 years for men, and for the effects of this brief, is rounded up to 60 years.