-80remedies, such as the action against a fraudulent res judicata. The State has provided evidence to this Court of having done so; j) the State’s argument regarding the “cases closed for non-suit by the plaintiff” was first presented for consideration by the parties and by the Court after over two years of the expiration of the time to answer the complaint, and it was not based on supervening facts, but, rather, it was grounded on facts that occurred in 1999 and 2000. Once the parties have formalized their conclusions in the closing arguments, it is not suitable for a party to introduce new arguments that were available during earlier stages. Anything to the contrary defeats the right to defense and cannot be cured by a submission of comments. The Commission places on record that it finds no element in the arguments advanced by the State, or in the succinct documents accompanying said arguments, to conclude that the fact that the cases were closed entails the termination of rights recognized in the challenged judgments, or affects their final nature, or the defendant’s obligation to comply with them. The Commission requests these arguments be dismissed as time-barred and untenable; and k) requests the Court to conclude that the Peruvian State has violated, to the detriment of the alleged victims in the instant case, the right to judicial protection enshrined in Article 25(2)(c) of the American Convention, in relation to Article 1(1) thereof, by having failed to comply with the final and enforceable judgments forming the subject-matter of the instant case; to declare the arguments made by the State seeking the resolution of a dispute between two government entities inadmissible; and to refuse to examine the State’s arguments in relation to the defects of the judgments at issue here. Argument by the common intervener for the representatives 206. As regards the alleged violation of Article 25(2)(c) of the Convention, with respect to Article 1(1) thereof, the common intervener pointed out that: a) court systems must have the decisions they adopt enforced. “If the State does not comply with the orders directing reparation of violations, it is affecting peaceful life in common and violating citizens’ rights to effective judicial protection.” Compliance with a court decision may not depend on the willingness or discretion of the party obliged, i.e. the State in this case; b) the orders directing the reinstatement of workers who were members of the SITRAMUN-LIMA to their jobs in the Municipality of Lima, the payment of their wages and other agreed benefits that they were not paid during the time of their dismissal, as well as the restoration of all other rights directly recognized to the SITRAMUN-LIMA, have not been complied with and the judicial remedies instituted to seek compliance with said judgments were completely ineffective. “As a result, the State incurs in international responsibility for the violation of the right to effective judicial protection, enshrined in Articles 8(1) and 25 of the Convention;” c) the refusal to comply with “the judgments pronounced in favor of the SITRAMUN-LIMA workers and the lack of an effective investigation and