54. Similarly, in the Case of Gelman v. Uruguay, the Court developed the so-called right to identity (which is not expressly established in the American Convention) on the basis of the provisions of article 8 of the Convention on the Rights of the Child, which establishes that this right includes, among other elements, the right to nationality, to a name, and to family relationships. Thus, the alleged violations of the rights recognized in Articles 3, 17, 18, 19 and 20 of the Convention were interpreted pursuant to the corpus juris of the law concerning children, especially articles 7, 8, 9, 11, 16 and 18 of the Convention on the Rights of the Child. 92 55. Meanwhile, in the Case of the Massacres of El Mozote and nearby places v. El Salvador, the Court complemented its case law with regard to the right to private property established in Article 21 of the Convention when referring to Articles 13 and 14 of Protocol (II) Additional to the 1949 Geneva Conventions relating to the Protection of Victims of NonInternational Armed Conflicts of 8 June 1977. 93 Subsequently, in the Case of the Massacre of Santo Domingo v. Colombia, the Court interpreted the scope of the same Article 21 using treaties other than the American Convention. Thus, it referred to Rule 7 of Customary International Humanitarian Law regarding the distinction between civilian objects and military objectives and Article 4.2.g of Protocol II, concerning pillage, 94 to provide content to the right to property established in Article 21 of the American Convention. 56. As can be observed from these examples of inter-American case law, it has been the reiterated practice of the Inter-American Court to use international instruments and sources other than the Pact of San José to define the content and even to expand the scope of the rights established in the American Convention and to stipulate the obligations of the States, 95 since the said international instruments and sources form part of a very comprehensive international corpus juris on the matter; also using the Protocol of San Salvador. The possibility of using the Protocol of San Salvador to give content and scope to the economic, social and cultural rights derived from Article 26 of the American Convention, in relation to the general obligations established in Articles 1 and 2 of this instrument, is viable in the way in which the Inter-American Court has been using them to provide content to many treaty-based rights using treaties and sources other than the Pact of San José. Thus, it could also use the Protocol of San Salvador, together with other international instruments, to establish the content and scope of the right to health protected by Article 26 of the American Convention. B) Articles 26 and 29 of the American Convention in light of the pro persona principle 57. Up until now, the Inter-American Court has used different aspects of the corpus juris on the right to health in order to found its arguments on the scope of the right to life or personal integrity, using the concept of decent life or another type of analysis based on the relationship between health and these civil rights (see supra para. 13). This argumentation strategy is valid and has permitted significant progress in inter-American case law. However, the main problems of this argumentation technique is that it prevents an in-depth 92 Cf. Case of Gelman, supra, paras. 121 and 122. 93 Cf. Case of the Massacres of El Mozote and nearby places v. El Salvador. Merits, reparations and costs. Judgment of October 25, 2012 Series C No. 252, para. 179. 94 Cf. Case of the Massacre of Santo Domingo v. Colombia. Preliminary objections, Merits and reparations. Judgment of November 30, 2012. Series C No. 259, paras. 270 to 272. 95 For example, The Progress Indicators in Respect of Rights Contemplated in the Protocol of San Salvador, OEA/Ser.L/XXV.2.1, Doc 2/11 rev.2, December 16, 2012, could also be used. 19