4 within internal armed conflicts. This is precisely the case in Guatemala, in the case under analysis. In this context it is important to note an aspect of the Rome Statute created by the International Criminal Court. It recognizes the practices that violate the human rights of women that have historically occurred in situations of armed conflict or disturbances (rape, sexual slavery, forced prostitution, forced pregnancy, forced sterilization or other sexual abuses of comparable gravity) as part of the crimes of genocide, crimes against humanity, and of war. And this aspect occurs in the case of Las Dos Erres Massacre. It is extremely important to apply the Convention of Belém do Pará in the case of Las Dos Erres Massacre, since the former defines violence against women; it recognizes women’s rights to life without violence and establishes that violence against them is a violation of human rights, establishing this right both in the public and the private realm. It may be asserted that the application of the gender perspective enriches the manner of looking at reality and acting on it, hence the need to mention it and apply it in the case of Las Dos Erres. In terms of human rights, it allows, among other things, to visualize the inequities construed artificially, socio-culturally, and to better detect the specificity in the protection needed by those who suffer inequality or discrimination. Thus, it offers large advantages and possibilities for the effective protection of individuals and, concretely, of women. The preamble of the Convention of Belém do Pará recognizes that “violence against women is an offense to human dignity and a manifestation of the historically unequal power relations between women and men.” The case of Las Dos Erres shows that this inequality indeed exists; therefore it is important to apply it. I am convinced that the Jurisprudence of the Inter-American Court of Human Rights should continue to set precedents in this direction. The importance of recognizing the specific violations of women’s human rights within the framework of the InterAmerican system lies in the development of specific standards to protect women (Declaration and Plan of Action of Vienna 1993 and IV World Conference on Women [Beijing, 1995 and others.]) This consideration should lead us to propose more concrete aspects in relation to reparation measures, and, concretely, of non-repetition, for example: a) the State of Guatemala must intensify and expand the existing actions to train officers, particularly those in the National Civil Police and the Public Prosecutor’s Office, on the causes, nature and consequences of gender violence; b) the State of Guatemala must guarantee that the impact and consequences of acts of violence committed against women during the internal armed conflict are adequately contemplated in the National Compensation Plan (“Plan Nacional de Resarcimiento”); c) the State of Guatemala must implement training programs on women’s rights and particularly on the right to a life free of violence, geared toward personnel in the public force, the army and public institutions; d) the State of Guatemala must implement all measures of protection and prevention to guarantee women a life free of violence and measures to avoid abuse and rape of women under federal, police, or military custody, as a form of torture. 3. Access to information and the State Secrets in cases of grave human rights violations: the judgment establishes in number 144 that “all authorities are forced to collaborate in the gathering of proof and should therefore provide the judge of the cause all information required and abstain from acts that imply obstruction in the investigation process.” In this regard, it is important to refer specifically to the obligation of the Guatemalan Army to deliver documents relating

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