12 characteristics similar to those of the expropriated property. They stated their disagreement with the State regarding the fact that an expropriation encumbers and reduces the value of the property, reason for which they hold the thesis that said act can in no case affect the just compensation.20 The representatives, in the merits and reparations stage, stated that the value of the property may in no case be less than US$130.60 (one hundred and thirty dollars with sixty cents of the United States of America) per square meter, including the value of the eucalyptus forest, and they stated that the value of the just compensation for the property, including the value of the eucalyptus forest, ascends to a total of US$84,326,787.5021 (eighty four million three hundred and twenty-six thousand seven hundred and eight seven dollars of the United States of America with fifty cents) plus interests. Additionally, they stated at the public hearing of October 19, 2007, that an adequate mechanism to determine the scope of the reparation could be the delivery of alternative properties of the same size and quality.22 38. Subsequently, the representatives, in their brief on reparations, stated that, according to the report of the expert Jakeline Jaramillo Barcia, the market value of the property prior to the public declaration was of US$42,180,504.47 (forty two million one hundred and eighty thousand five hundred and four dollars of the United States of America with forty seven cents), considering only the valuation of the property’s soil. They added that the value of the forest plantation should be added to the established amount, and that it had a value of US$1,174,735.00 (one million one hundred and seventy four thousand seven hundred and thirty five dollars of the United States of America). Therefore, the representatives requested a total value of US$43,355,239.47 (forty three million three hundred and fifty five thousand two hundred and thirty nine dollars of the United States with forty seven cents) in just compensation. They added in the brief of reparation claims that the (compound) interests accrued should be added to that amount.23 39. The State indicated that it would acknowledge a “compensation […] set within the framework of the national or Inter-American litigation based on an unbiased expert assessment in accordance with the actual value of the property without taking into account the added value [that] adjusts to the country’s reality[, …] to the annual municipal budget, and, especially under the criterion stated by the Court [… that] a possible compensation must not imply an enrichment or impoverishment of the victim.” It stated that the values demanded by the victim as compensation are excessive, because they correspond to the value per square meter of properties that have increased their value in the urban area throughout the years and may be freely submitted to the laws of offer and demand. It added that the representatives have ignored the fact that the properties in question do not have a future housing development, and therefore, they cannot be assessed as properties in the free market. It argued that neither in the judgment issued in the domestic jurisdiction or in the expert report by Jakeline Jaramillo Barcia, presented by the representatives, was it taken into consideration that the property in question is located within an ecological protected area, pursuant with that stated by this Court in the Judgment on the Merits.24 The property has minimum occupation 20 Pursuant to the Centre for Settlement of Investment Disputes in the Case of Santa Elena versus Costa Rica, in conformity with that expressed by the representatives in the public hearing held on October 19, 2007, in the city of Bogota, Colombia. 21 The amount is a multiplication of the total area by the price of m2 (645.687,5 x 130,6). 22 The representatives affirmed that the aforementioned could be possible based on that established in indigenous cases against Paraguay (public hearing held on October 19, 2007 in the city of Bogotá, Colombia). 23 The representatives requested the sum of U.S. $ 56,730,723.69 (fifty-six million, seven hundred and thirty thousand, seven hundred and twenty-three dollars of the United States of American and sixty-nine cents) and compound interest accrued during the time that the State has not paid the just compensation, namely from May 13, 1991 until May 13, 2009. They said that if payment is made after the due date, interest should be calculated under the same formula until the date in which payment is actually carried out. 24 Cf. Case of Salvador Chiriboga V. Ecuador. Preliminary Objection and Merits. Judgment of May 6, 2008. Series C No. 179, para. 71