3 Constitution established a guarantee that laws would not be retroactive except in criminal issues where retroactivity would be favorable.” 3. The Commission requested that the Court “give full weight to the State’s acknowledgment of responsibility” and declare a violation of Article 25 (Judicial Protection) of the American Convention, with regard to Article 1(1) (Obligation to Respect Rights) of the American Convention, all to the detriment of the 233 alleged victims in this case. The Commission also requested that the Tribunal order the State to adopt measures of reparation, as well as to reimburse for costs and expenses. 4. On April 14, 2010, the representative of the alleged victims,5 Mr. Juan José Tello Harster (hereinafter “the representative”), filed a brief of pleadings, motions, and evidence (hereinafter, “brief of pleadings and motions”), under the terms of Article 40 of the Rules of Procedure. In addition to the Commission’s position in the application, the representative requested that the Court declare the State responsible for the violation of the rights acknowledged in Articles 21(1) and 21(2) (Right to Private Property) in relation to Article 1(1) of the American Convention and specified its request for reparations, costs, and expenses. 5. On June 22, 2010, the State filed a brief answering the application and providing comments on the brief of pleadings and motions (hereinafter, “answer to the application”) under the terms of Article 41 of the Rules of Procedure. In that brief, the State indicated that it “only acknowledges its international responsibility with regard to the violation of Article 25 of the American Convention, in regard to its retroactive application of Law Decree No. 25876.” In this sense, it specified that, “[t]his acknowledgment does not imply total acceptance of the arguments presented by the alleged victims with regard to the amount of the material damage.” It also indicated that “the violation of Articles 21(1) and 21(2) of the Convention has not taken place,” as the State “can legitimately limit or restrict the right to property, for not all restrictions necessarily imply violations.” On February 25, 2010, the State designated Mrs. Delia Muñoz Muñoz as its Agent in this case. 6. On July 19 and 23, 2010, the representative and the Commission, respectively, presented their observations on the State’s acknowledgment of international responsibility in this case, in keeping with Article 62 of the Rules of Procedure. II PROCEEDING BEFORE THE COURT 7. The State and the representative were notified of the application on February 17, 2010. 8. Through Order of September 8, 2010,6 the Acting President of the Court for this case (hereinafter, “the President”) ordered that statements be rendered before a public notary (affidavit) by two experts and called the parties to a public hearing to hear testimony of a witness proposed by the State, as well as the final comments and final oral arguments on the merits, reparations and costs in the case from the Commission, the representative and the State. 5 On March 10, 2010, the SIFUSE board of directors granted power of attorney to litigate in this international proceeding as lead representative to Juan José Tello Harster. He was granted authority to represent the union and all two hundred and thirty-three workers who are the alleged victims. Moreover, Mr. Guillermo Darío Romero Quispe was designated as alternate representative. Power of attorney to litigate on March 10, 2010 (case file of annexes to the brief of pleadings and motions, tome VI, annex 7, folios 1832 to 1840). 6 2010. Order of the Acting President of the Inter-American Court of Human Rights for this case, September 8,