The brief of August 22, 2011, in which the State presented a report on
compliance with the measure of reparation concerning medical and psychological
treatment and submitted the document entitled “Proposed initial method of attention to
the victims.”
The communications of May 6 and August 16, 2011, forwarded by Deycci Marcela
Salgado Bolaños, daughter of Arturo Salgado Garzón, victim in the case of the La
Rochela Massacre v. Colombia, in which she asked for the “support” of the Court in view
of the “complex” health situation of her father and “the serious health conditions” of her
aunt, María Sara Salgado.
The briefs of July 8 and October 3, 2011, in which the representatives presented
observations on the State’s report on compliance with the measure of reparation on
medical and psychological attention in the nine Colombian cases (supra having seen
paragraphs 5 and 6).
The briefs of August 16, 2010, June 22, 2011, and January 26, 2012, in which
the Commission presented its observations on the State’s report on medical and
psychological attention in the nine Colombian cases.
One of the inherent attributes of the jurisdictional functions of the Court is to
monitor compliance with its decisions.
Colombia has been a State Party to the American Convention on Human Rights
(hereinafter “the Convention” or “the American Convention”) since July 31, 1973, and
accepted the binding jurisdiction of the Court on June 21, 1985.
As established in Article 67 of the American Convention, the State must comply
with the judgments of the Court fully and promptly. In addition, Article 68(1) of the
American Convention stipulates that “[t]he States Parties to the Convention undertake to
comply with the judgment of the Court in any case to which they are parties.” To this
end, the State must ensure implementation of the Court’s decisions in its judgments at
the domestic level.2
The States Parties to the Convention must ensure compliance with its provisions
and their inherent effects (effet utile) within their respective domestic legal systems.
This principle is applicable not only with regard to the substantive norms of human rights
treaties (that is, those which contain provisions concerning the protected rights), but
also with regard to procedural norms, such as those referring to compliance with the
decisions of the Court. These obligations shall be interpreted and applied so that the
protected guarantee is truly practical and effective, bearing in mind the special nature of
human rights treaties.3
I. Implementation of the measure of reparation in 2010
The private hearing on monitoring compliance held in relation to this measure of
reparation (supra having seen paragraph 2) concluded with the commitment of the

Cf. Case of Baena Ricardo et al. Competence. Judgment of November 28, 2003. Series C No. 104,
para. 60 and Case of the Pueblo Bello Massacre v. Colombia. Monitoring compliance with judgment. Order of
the Inter-American Court of Human Rights of January 23, 2012, third considering paragraph.

Cf. Case of Ivcher Bronstein v. Peru. Competence. Judgment of the Inter-American Court of Human
Rights of September 24, 1999, para. 37; Case of Castañeda Gutman. Monitoring compliance with judgment.
Notice of a public hearing. Order of the President of the Inter-American Court of Human Rights, of January 18,
2002, fifth considering paragraph.

Select target paragraph3