compensation, measures of restitution, rehabilitation and satisfaction, and guarantees of nonrepetition, have special relevance for the harm caused.185
139. This Court has established that the reparations must have a causal nexus with the facts of
the case, the violations declared, the harm proved, and the measures requested to redress the
respective harm. Consequently, the Court must observe these concurring factors in order to rule
appropriately and in keeping with law.186
140. Bearing in mind the violations declared in the previous chapters, in light of the criteria
established in its case law concerning the nature and scope of the obligation to make reparation, 187
the Court will proceed to examine the claims presented by the Commission and the representatives,
together with the arguments of the State, in order to then establish measures aimed at providing
reparation for said violations.
A. Injured party
141. The Court reiterates that, pursuant to Article 63(1) of the Convention, anyone who has been
declared a victim of the violation of any right recognized therein, is considered an injured party.
Therefore, this Court considers Miguel Ángel Rodríguez Revolorio, Miguel Ángel López Calo and Aníbal
Archila Pérez as "injured parties," who, as victims of the violations declared in Chapter VIII, shall be
the beneficiaries of the reparations ordered by the Court.
B. Rehabilitation and satisfaction measures
b.1 Rehabilitation measures
142. The Commission requested that the reparation measures include rehabilitation for Mr.
Rodríguez Revolorio and Mr. López Calo.
143. The representatives requested the Court to order the State of Guatemala to provide medical
and psychological care in specialized centers at no additional cost and free of charge to the alleged
surviving victims.
144. The State stated that it provides medical and psychological care through public health
centers, which are at the service of all the country's inhabitants.
145. The Court establishes the obligation of the State to provide the medical and psychological
treatment required by Mr. Rodríguez Revolorio in Guatemala, immediately and free of charge, with
prior informed consent, and for as long as necessary, including the free provision of medication.
b.2 Measures of satisfaction
(i) Publication of the Judgment
Cantoral Benavides v. Peru. Reparations and Costs. Judgment of December 3, 2001. Series C No. 88, paras. 79-81,
and Case of Ramírez Escobar et al. v. Guatemala, supra, para. 371.
186
Case of Ticona Estrada v. Bolivia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 191,
para. 110, and Case of Coc Max et al (Xamán Massacre) v. Guatemala, supra, para. 144.
187
Cf. Case of Velásquez Rodríguez v. Honduras. Reparations and Costs, supra, paras. 25-27, and Case of Coc Max et
al (Xamán Massacre) v. Guatemala, supra, para. 145.
185
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