cases in which it accepted the competence only covered subsequent acts or acts that began to be executed after the date on which the [respective] declaration was deposited.’” The Court observed that “[t]he ‘Purpose of the application’ described by the Commission did not, in principle, include petitions that were related to the violation of the victim’s right to life or to humane treatment – facts that occurred prior to Nicaragua’s acceptance of competence.” Consequently, it “found that the preliminary objection was inadmissible and declared itself competent to hear the […] case.” 14 A similar situation occurred in the case of Moiwana v. Suriname, the facts of which refer to a massacre committed on November 29, 1986. Suriname had recognized the Court’s competence on November 12, 1987. The Court rejected the preliminary objection of lack of temporal competence filed by the State and found that “[t]he examination of the compatibility of the acts and omissions of the State in relation to [the] investigation [of the facts] with Articles 8, 25 and 1(1) of the Convention falls within the competence of this Court.” 15 Likewise, in the case of García Prieto et al. v. El Salvador, the State filed an objection based on the Court’s lack of temporal competence, because it had accepted the Court’s competence on June 6, 1995, and the death of Ramón Mauricio García Prieto occurred on June 10, 1994. When recognizing the Court’s competence, El Salvador had declared that this competence “covers only and exclusively subsequent legal acts or facts, or legal acts or facts that began to be executed after the date of the deposit” of its acceptance. The Court rejected the preliminary objection partially, finding that, “in light of the content of Articles 8(1) and 25(1) of the Convention, [the Court] had competence to analyze the acts or omissions that occurred during the judicial or police proceedings that can be characterized as ‘independent facts’ and that took place when the Court had temporal competence.” 16 32. The precedent should also be cited of the case of Almonacid Arellano et al. v. Chile, which originated in the extrajudicial execution of Mr. Almonacid Arellano on September 17, 1973. The State, based on the temporal limitation of the Court’s competence, filed an objection of lack of temporal competence, which the Court rejected. Among other matters, the Court indicated that it had “considered that, during a proceedings, independent acts may occur that could constitute specific and autonomous violations involving denial of justice,” and that certain facts indicated by the Commission and the representatives, “could constitute autonomous violations of Articles 8(1) and 25 of the Convention, in relation to Article 1(1) of this instrument.” It also stated that “[t]he start of the execution of the supposed failure to comply with Article 2 of the American Convention occurred when the State undertook to adapt its domestic legislation to the Convention; in other words, when it ratified the Convention. 17 33. More recently, in the case of the Río Negro Massacres v. Guatemala, the Court noted that “the State seeks to prevent the Court from examining the human rights violations that took place prior to March 9, 1987, the date on which Guatemala accepted the Court’s contentious jurisdiction, that are not of a continuing or permanent nature and that do not persist until [today].” The Court considered that it was competent with regard to certain facts, including “the absence of an impartial and effective investigation into the events [and] the effects on the personal integrity of the next of kin and survivors in relation to the investigation of the facts,” and that it could “analyze […] the arguments concerning the 14 Cf. Case of Genie Lacayo v. Nicaragua. Preliminary objections. Judgment of January 27, 1995. Series C No. 21, paras. 21, 25 and 26. 15 Cf. Case of the Moiwana Community v. Suriname, supra, paras. 43 and 44. 16 Cf. Case of García Prieto et al. v. El Salvador. Preliminary objections, merits, reparations and costs. Judgment of November 20, 2007. Series C No. 168, paras. 31, 45 and 46. 17 Cf. Case of Almonacid Arellano et al. v. Chile, supra, paras. 48 to 51. 12