that it carries out in its capacity as a supervisory organ of the American Convention.28 Articles 45 and 46 of Commission’s Rules of Procedure regulate the powers of this organ regarding the submission of a case to the Court. 39. It is incumbent on the President of the Court to corroborate that, when submitting the case, the Commission has indicated the said reasons and observations, but this does not entail making a preliminary analysis of the merits of the said reasons.29 The Court also considers that, even when the State is implementing one or more of the recommendations made by the Commission, the latter may consider that there are still sufficient grounds to submit the case to the Court owing to the failure to comply with other recommendations that it considers fundamental in each case. 40. The Court observes that, when submitting this case, the Commission referred to the State’s report regarding implementation of the recommendations made in the Merits Report. Among other observations, the Commission recognized and appreciated that the State had taken important steps in implementing two of the recommendations (relating to training for the armed forces, and special protection programs for journalists at risk and investigation of offenses against them). However, the Commission observed that there had been “no compliance” with the recommendations to provide “comprehensive reparation for the victims” and the obligation to investigate and to punish those responsible for the violations. In its brief submitting the case, the Commission indicated that “it submit[ted] to the jurisdiction of the Court all the facts and humans rights violations […] described in Merits Report No. 136/10” and asked the Court to order six measures of reparation, which concur precisely with the six recommendations made by the Commission in the said report. 41. The President of the Court considered that, when submitting the case, the Commission had fulfilled the requirements under Article 35 of the Court’s Rules of Procedure and, consequently, requested the Secretariat to notify the submission of the case. The Court supports the President’s action and, regarding the Commission’s omission to provide a copy of the State’s report on compliance with the recommendations made by the Commission on that occasion, the Court notes that the latter indicated that the failure was due to an inadvertent error and that the State forwarded this report to the Court as an attachment to its brief in answer to the submission of the case. The State also provided the Court with additional information related to progress in compliance with the said recommendations. 42. Based on the above findings, this Court reaffirms that the broad acknowledgment of responsibility made by Colombia, as well as the progress made in implementing recommendations made by the Commission in its Merits Report and the above-mentioned arguments of the State in this regard, will be assessed by the Court when it rules on the measures of reparation requested by the Commission and the representative of the victims (infra Chapter XII). B) The factual framework of the case Arguments of the State and observations of the representative 28 Cf. Case of the 19 Tradesmen v. Colombia. Preliminary objection. Judgment of June 12, 2002. Series C No. 93. para. 31. 29 Cf. Case of the 19 Tradesmen v. Colombia. Preliminary objection, para. 31, and Case of Gomes Lund et al. (Guerrilha do Araguaia) v. Brazil. Preliminary objections, merits, reparations and costs. Judgment of November 24, 2010. Series C No. 219, para. 27. 16

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