10 27. In sum, the right to freedom of association has been protected by connectivity, subsuming it in the right to freedom of association recognized in Article 16 of the American Convention (indirect justiciability by connectivity). However, in the instant case, as we shall see in the following section, the Inter-American Court extended the protection of labor associations and institutions that are not labor unions and, contrary to the cases referred to above, the InterAmerican Court addressed directly the right to the freedom of association of labor from the perspective of Article 26 of the American Convention. III. THE RIGHT TO THE FREEDOM OF ASSOCIATION OF LABOR FOR THE PROTECTION AND PROMOTION OF WORKERS’ INTERESTS AS PART OF THE RIGHT TO WORK 28. In the judgment, the Inter-American Court concluded that Articles 16(1) and 26 of the American Convention had been violated, in relation to Articles 8, 11, and 13 of this instrument, to the detriment of Mr. Lagos del Campos, as follows: 162. […] the Court finds that the dismissal of Mr. Lagos del Campo went beyond the violation of his individual right to freedom of association, because it deprived the workers of the Industrial Community of the representation of one of their leaders, especially in the election that should have been held under his supervision as president of the Electoral Committee. The Court also notes that, since Mr. Lagos del Campo’s dismissal was carried out in reprisal for his task of representation, this could have had an intimidating and threatening impact on the other members of the Industrial Community […].50 29. In this regard, even though I agree with the judgment, I believe it important to make some clarifications in relation to the violation of the right to freedom of association and its impact on labor matters. And this is taking into consideration that the judgment does not indicate the reasons why it relates Article 26 of the Pact of San José to the labor-related right to freedom of association for the protection and promotion of the victim’s interests, contained expressly in Article 45(c) of the OAS Charter, or its relationship to Article 16 of the American Convention.51 30. In the instant case, the Inter-American Court recognized that the issue of freedom of association in relation to labor unions is of particular importance. Moreover, Article 19(6) of the Protocol of San Salvador confers on the Inter-American Court the express competence to rule on violations of the State’s obligation to permit unions, federations and confederations to function freely, as established in Article 8(1)(a).52 In addition, the Inter-American Court referred to one aspect of labor union rights when it stated that “freedom of association in relation to labor unions is of the greatest importance for the defense of the legitimate interests of the workers, and is established in the corpus juris of human rights.53 However, Article 8(1)(a) of the Protocol of San Salvador does not include all the situations in which a violation could be declared when labor union association is affected. scope of Article 1(2), in relation to Articles 1(1), 8, 11(2), 13, 16, 21, 24, 25, 29, 30, 44, 46, and 62(3) of the American Convention on Human Rights, as well as of Article 8(1) A and B of the Protocol of San Salvador). Advisory Opinion OC22/16 of February 26, 2016. Series A No. 22, para. 92. 50 Cf. Case of Lagos del Campo v. Peru, supra, para. 162. In this regard, it should be noted that the judgment itself recognizes, in a synergetic manner, the relationship that exists between the American Declaration of the Rights and Duties of Man, the OAS Charter, the Inter-American Democratic Charter and the 1971 Convention on Workers’ Representatives, which also protects the right of workers to associate to defend their interests. Cf. Case of Lagos del Campo v. Peru, supra, para. 158 and footnote 230. 51 52 Cf. Case of Lagos del Campo v. Peru, supra, para. 157. Cf. Case of Lagos del Campo v. Peru, supra, para. 157; Case of Baena Ricardo et al. v. Panama, supra, paras. 156 and 158; Case of Huilca Tecse v. Peru, supra, paras. 67, 69, 70, 73, 75, 77, and Case of Cantoral Huamaní and García Santa Cruz v. Peru, supra, paras. 144, 145, 146 and Cf. ILO. Convention No. 87 on Freedom of Association and Protection of the Right to Organize, of June 17, 1948, and Convention No. 98 on Right to Organize and Collective Bargaining, of June 8, 1949. 53