-104e) despite of the existence of supranational rules that protect union privileges, and of the existence of a Collective Agreement signed by the parties which guaranteed the labor stability of the workers of the municipal corporation, the Municipalidad Metropolitana de Lima (Metropolitan Municipality of Lima) did not hesitate in implementing massive dismissals that affected more than 1,200 workers, including the 15 union leaders, who were sent 2 or 3 dismissal resolution notices, as in the case of the union leader Wilfredo Castillo-Sabalaga. 289. Arguments by the State The state alleged that it had not breached any obligation imposed by the Convention. Considerations of the Court 290. The common intervener did not allege violation of Article 16 of the Convention at the corresponding point in the procedure. However, the Court deems that the facts at issue in this case do not fall within the scope of Article 16 of the Convention, and therefore, the Court shall not deliver opinion on the alleged violation of said Article. XII REPARATIONS APPLICATION OF ARTICLE 63(1) Obligation to repair 291. Arguments by the Commission a) as regards the beneficiaries of the reparations: i. the persons entitled to reparations are “the 1734 workers of the Municipality of Lima that are members of the SITRAMUN” and the former workers of the ESMLL corporation. The persons whose names are indicated in the footnotes of the application, when referring to each particular judgment, must be considered the beneficiaries of the reparations. ii. the position adopted by the State after its answer to the application, has resulted in some new disputes regarding the lists of the victims, and therefore a judicial determination of such issue is needed; b) as regards pecuniary damage, the Commission requested the Court to order Peru: i. to reinstate the workers of the Municipality of Lima, members of the SITRAMUN, that were unfairly dismissed, or to pay them a compensation in case it is not possible to reinstate them to the same job they had or to a new position; ii. to pay the workers of the Municipality of Lima, members of the SITRAMUN, that were dismissed, the amounts of their wages or salaries, bonuses, allowances and other benefits unduly lost;