f) On the basis of two cases - those of Rafael Rojas and Damas Vega - the Commission argued that there is “generalized situation” regarding the conditions of detention at the CAI La Reforma and concluded the violation of the right to personal integrity to the detriment of all the victims in this case who have served their sentence at said prison facility, as well as Rojas Madrigal due to the lack of access to health services. All this is an illogical, unfounded reasoning, lacking in evidence. It pointed out that in order to comply with the Constitutional Chamber’s ruling on drinking water, food, prison facilities and health care, the State provided extensive information that was not included by the Commission in the submission of the case, and it even “affirmed that the State had not provided information on compliance with the recommendations.” g) The Commission did not comply with Article 35 of the Rules of Procedure, because when it submitted the case it did not present all the documentation included in the file, especially the State’s briefs submitted after the Merits Report. h) The common interveners SIPDH submitted two briefs to the Court containing pleadings and motions in violation of procedure and abuse of the system. 62. The Commission considered that the arguments submitted by the State were inadmissible. First, on the form of joinder of the cases, it recalled that according to its Rules of Procedure it has the power to join cases in the same file if they “concern similar facts, involve the same persons or reveal the same pattern of conduct.” In the Admissibility Report, it joined the eight petitions, since they all alleged that the State had violated the judicial guarantees established in Articles 8 and 25 of the Convention and, in particular, Article 8(2)(h), “for the alleged lack of an ordinary remedy for the comprehensive review of convictions handed down against the alleged victims.” For its part, the State, in its only communication containing arguments on the merits, dated June 2013, did not question the joinder of cases. In addition, it noted that the State did not explain specifically the nature of the alleged harm caused to its defense by the joinder of the cases. 75 63. Second, with respect to the failure to include all the documentation contained in the file when submitting the case to the Court, it explained that, due to an involuntary error in the process of digitalizing the information, it did not forward to the Court the documentation submitted by the parties after having issued the Merits Report. However, it sent said documentation later, in its observations to the preliminary objections, and without affecting the State’s right of defense, since during the proceedings before the Commission, the information was duly transmitted to the parties. Third, regarding the alleged inadequate legal analysis, it argued that this allegation does not have the character of a preliminary objection but rather questions the analysis of the merits carried out by the Commission. Fourth, of the prosecutor's indictment, since these are very different from the proven facts of the conviction. During the public hearing on preliminary objections, it pointed out the contradictions of the Commission in its basic analysis, since paragraph 198 of the Merits Report states that “the determination as to whether or not the right to appeal the judgment has been violated must be examined on a case by case basis”; however, in paragraph 207 it considered it “unnecessary to delve deeper into the specific allegations raised by the alleged victims in their petitions (…), or into the response to said allegations received by them.” 75 During the public hearing on preliminary objections it explained that, according to its Rules of Procedure, “[t]he use of the joinder mechanism does not require that the cases be identical in all aspects [,] which would be impracticable, but rather that they involve similar facts or follow the same pattern of conduct.” In this regard, and without prejudice to the other alleged violations declared in the Merits Report, it held that Article 8(2)(h) of the Convention “is the central violation in the instant case and constitutes a clear common and cross-cutting element in all the matters that comprise it [,] which is sufficient to justify the joinder.” Finally, in the hearing on preliminary objections and in its final written arguments, it recalled that the joinder of cases has been applied on numerous occasions and that several of these cases have even been heard by the Court. 25