responsible for the violation of the rights established in Articles 5(1), 5(2) and 11(2) of the Convention, in relation to the obligations established in Article 1(1) of this instrument, to the detriment of an indeterminate number of women who were in the village of El Mozote at the time of the alleged massacre. The Commission also emphasized that the sexual abuse to which detained women are subjected constitutes torture. In this regard, the Commission referred to the complementary nature of Articles 5 and 11 of the American Convention in cases of rape because, in addition to affecting the victim’s physical, mental and moral integrity, it violates her dignity, invades one of the most intimate spheres of her life – that of her sexual and physical space – and deprives her of the ability to make autonomous decisions regarding her body. 131. The Commission indicated that several people had survived the massacres of El Mozote and nearby places, who were also next of kin of the victims executed, and that just the loss of their loved ones in circumstances such as those described in this case would allow inferring suffering incompatible with Article 5(1) of the Convention. In addition, the Commission referred to specific circumstances that, owing to the nature of the facts, had been endured by the surviving next of kin during and after the massacres, causing serious effects on the mental and moral integrity of the surviving next of kin. Consequently, the Commission concluded that the State was responsible for the violation of the right to mental and moral integrity established in Article 5(1) of the Convention, in relation to the obligations established in Article 1(1) of this instrument, to the detriment of the surviving next of kin. 132. The Commission claimed that several houses in El Mozote, La Joya, Ranchería, Toriles, Jocote Amarillo and Cerro Pando had been set on fire by the same soldiers when perpetrating the massacres. In addition, in some places, the members of the military units in charge of the operation had stripped the victims of the possessions they were carrying or the belongings found in their homes. Similarly, several survivors declared that, upon returning from their hiding place to look for their next of kin, they found the bodies of the animals that were their means of subsistence. Consequently, the Commission considered that the events described constituted a violation of the right to property established in Article 21(1) and 21(2), in relation to the obligations established in Article 1(1) of this instrument, to the detriment of the executed victims who had been stripped of their belongings, as well as of the survivors who lived in the villages and cantons where the massacres had been committed and whose homes were destroyed or their means of subsistence seized or eliminated. 133. The Commission argued that, as a result of the terror caused among the population, as well as the total destruction of the places where the massacres occurred and the resulting impossibility of continuing to live there, many people left for the Republic of Honduras to seek refuge, returning to El Salvador around the beginning of the 1990s. In this regard, it considered that this situation should be included within the definition of enforced displacement and that, because it occurred as a direct consequence of the massacres, the State was responsible for the violation of the right established in Article 22(1) of the Convention, in relation to Article 1(1) of this instrument, to the detriment of the persons identified who had taken refuge in the Republic of Honduras. 2) Arguments of the representatives 134. The representatives argued that the procedural obligation of the State to investigate the violations of the rights to life and to personal integrity of the presumed victims of the alleged massacre was independent of the substantive obligation arising from these provisions. In this regard, they indicated that, despite the gravity of the events, since the date on which the Court had competence to rule on the alleged facts, the State had not taken a single measure on its own initiative to establish the truth of what happened. Accordingly, they asked the Court to declare that the State was responsible for the violation of the rights contained in Articles 4 and 5 of the Convention, in relation to Article 1(1) of this instrument. In their final arguments, the representatives asked to the Court to declare the aggravated responsibility of the State for the creation and application of the strategy of “taking the water away from the fish” or “scorched earth”; to declare the State responsible for the violation of the right to life of the victims of the 41