punished.14 The tolerance of these groups by certain sectors of the Army has been denounced by agencies of the State itself.15 35. The Commission notes that initially it was the State itself that encouraged the creation of self-defense groups for specific purposes but they expanded and began to act outside the law, together with the collaboration or acquiescence of State agents. The Court has observed that such "paramilitary groups are responsible for numerous murders [...] and for the majority of human rights violations in general" committed in Colombia.16 36. This situation has led the Commission to establish that, for the purpose of determining the international responsibility of the State under the American Convention, where paramilitaries and members of the Army carry out joint operations with the knowledge of senior officers, or when the paramilitaries operate thanks to the collaboration or acquiescence of the Security Forces, members of paramilitary groups should be considered to be acting as State agents.17 37. For its part, the Inter-American Court has verified, in different periods and geographical contexts, the existence of links between members of Colombia's Armed Forces and paramilitary groups. A combined analysis of the cases decided by the Commission and later by the Inter-American Court points to the existence of a link between paramilitary groups and members of the security forces regarding human rights violations such as extrajudicial executions, forced disappearances, torture and cruel, inhuman or degrading treatment, forced displacement, among others. This link is manifested through either direct actions of support, collaboration and coordination, or through the omissions of members of the security forces that have favored the actions of paramilitary groups. Among such cases are the Case of the 19 Merchants18, the Mapiripán Massacre, 19 the Ituango and El Aro Massacres,20 Cepeda Vargas,21 among others. 38. Specifically in the Case of the Rochela Massacre, the Court recapitulated the instances for attribution of international responsibility to the State for acts perpetrated by paramilitaries. First, it reiterated the international responsibility of Colombia i) for having issued a legal framework through which the creation of self-defense groups led to paramilitarism; and ii) the failure to adopt all necessary measures to effectively end the risk created by the State itself due to such regulations.22 Secondly, it said it had found Colombia responsible for breach of its duty of protection by failing to take effective preventative and 14 IACHR, Third Report on the Situation of Human Rights in Colombia. OEA/Ser.L/V/II.102 Doc. 9 rev. 1, February 26, 1999. Cap. I, paras. 17-19, http://www.IACHR.org/countryrep/Colom99sp/indice.htm. See also Report of the Office in Colombia of the United Nations High Commissioner for Human Rights, April 2000, para. 30. See also IACHR. Report No. 75/06, Jesús María Valle Jaramillo, October 16, 2006, para. 62. 15 IACHR, Third Report on the Situation of Human Rights in Colombia. OEA/Ser.L/V/II.102 Doc. 9 rev. 1, February 26, 1999, Cap. IV, paras. 37-239. IACHR. Report No. 75/06 Jesús María Valle Jaramillo, October 16, 2006, para. 62, at http://www.IACHR.org/countryrep/Colom99sp/indice.htm. 16 I/A Court H.R., Case of the "Mapiripán Massacre" v. Colombia. Merits, Reparations and Costs. Judgment of September 15, 2005. Series C No. 134, para. 96.18 and I/A Court H.R.. Case of the Ituango Massacres v. Colombia. Preliminary Objection, Merits, Reparations and Costs. Judgment of July 1, 2006 Series C No. 148, para. 125. 17 IACHR. Report No.37/00 Monsignor Oscar Arnulfo Romero and Galdámez, para. 64. IACHR. Report No. 75/06 Jesús María Valle Jaramillo, October 16, 2006, para. 63. 18 109. I/A Court H.R., Case of the 19 Merchants v. Colombia. Merits, Reparations and Costs. Judgment of July 5, 2004. Series C No. 19 I/A Court H.R., Case of the "Mapiripán Massacre" v. Colombia. Merits, Reparations and Costs. Judgment of September 15, 2005. Series C No. 134. 20 I/A Court H.R., Case of the Ituango Massacres v. Colombia. Preliminary Objection, Merits, Reparations and Costs. Judgment of July 1, 2006 Series C No. 148. 21 I/A Court H.R., Case of Manuel Cepeda Vargas v. Colombia. Preliminary Objections, Merits, Reparations and Costs. Judgment of May 26, 2010. Series C No.213. 22 I/A Court H.R., Case of the Rochela Massacre v. Colombia. Merits, Reparations and Costs. Judgment of May 11, 2007. Series C No. 163, para. 78. 7