69 a) The indirect damage should be calculated based on the losses caused by the massacre to the families who lived in Plan de Sánchez at that time; namely, 40 households. These families lost their homes, domestic animals, basic grains, farm animals, clothes, cooking utensils, and furniture. The cost of each of these items in the market of the municipal capital of Rabinal and the cost of housing provided by “Hábitat Guatemala” should be used to calculate the amount of this compensation. Accordingly, they requested the Court to establish, in fairness, for indirect damage, the amount of US$7,062.78 (seven thousand and sixty two United States dollars and seventy-eight cents) for each household, which amounts to US$282,511.20 (two hundred and eight-two thousand five hundred and eleven United States dollars and twenty cents) for the 40 households; b) The inhabitants of Plan de Sánchez, and of the communities of Concul, Chipuerta, Joya de Ramos, Raxjut, Volcanillo, Chichupac, Coxojabaj, Las Tunas, Las Minas, Las Ventanas, Ixchel, Chiac and Rabinal, victims of the massacre, were farmers; most of them farmed their own land, which was of different dimensions. They used the product of their harvest for their own subsistence and sold any surplus; their earnings depended on variables, such as the size and quality of their land, and market prices; c) After the events of July 1982, the survivors of the massacre who had lived in Plan de Sánchez were obliged to displace outside the community, had no access to any income, and were forced to patrol in the PAC from 1985 to 1996. The next of kin of those executed in the massacre who did not live in Plan de Sánchez were also obliged to carry out patrols from November 11, 1981, until 1996; d) The loss of earnings should be calculated on the basis of the minimum wage for agricultural activities in force in Guatemala in 2004, because its increase has not been constant as regards the quetzal’s devaluation in relation to the dollar and, owing to the dimensions of the case, it is not feasible to make specific calculations according to the yearly variations in the minimum wage. To this should be added the payment of social benefits according to Decree 76-78, in force since 1978; e) For “loss of earnings,” the Court should establish a total of US$1,901,643.80 (one million nine hundred and one thousand six hundred and forty-three United States dollars and eighty cents). This amount should be divided into US$466,143,80 (four hundred and sixty six thousand one hundred and forty-three United States dollars and eighty cents) corresponding to the 40 survivors who lived in Plan de Sánchez at the time of the facts and US$1,435,500.00 (one million four hundred and thirty-five thousand five hundred United States dollars) for the 150 next of kin of those executed in the massacre who lived in other communities; and f) The State should set up a survivor identification committee to identify all those with a right to reparation; and also establish an adequate reserve fund, so that, when these people have been identified, it contains US$11,204,530.00 (eleven million two hundred and four thousand, five hundred and thirty United States dollars) to pay the amounts that the Court orders for pecuniary and non-pecuniary damages to the beneficiaries of the judgment.

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