I. INTRODUCTION OF THE CASE AND CAUSE OF THE ACTION 1. The case submitted to the Court. On September 11, 2019, the Inter-American Commission on Human Rights (hereinafter “the Inter-American Commission” or “the Commission”) submitted to the jurisdiction of the Inter-American Court the Case of Sandra Cecilia Pavez Pavez against the Republic of Chile (hereinafter “the State” or “Chile”). According to the Commission, the case concerns the alleged international responsibility of the State for the disqualification of Ms. Sandra Cecilia Pavez Pavez, owing to her sexual orientation, from teaching the subject of Catholic religion in a public educational establishment. The Commission indicated that the disqualification occurred on July 25, 2007, after the Office of the Vicar for Education of the Diocese of San Bernardo (hereinafter “the Vicariate for Education” or “the Vicariate of San Bernardo”) revoked her certificate of suitability. This document is a requirement of the Ministry of Education, pursuant to Decree 924 of 1983, for teachers to be able to work as Catholic religion teachers. According to the Commission, the certificate was withdrawn based on Ms. Pavez’s sexual orientation, and thus she was disqualified from holding the position of Catholic religion teacher. The Commission found that in this case the alleged victim was subjected to a difference in treatment based on her sexual orientation, without any justification that would pass a minimum scrutiny of objectivity and reasonableness, and was attributable to the State owing to a regulation that granted the religious authorities absolute powers in this matter. Therefore, the Commission concluded that the State of Chile “is responsible for violating [the right to] privacy and autonomy, the principle of equality and non-discrimination, access to public service under conditions of equality, the right to work, the right to obtain reasoned decisions and to judicial protection, established in Articles 11(2), 24, 23(1)(c), 26, 8(1) and 25 of the American Convention, in relation to the obligations established in Articles 1(1) and 2 thereof, to the detriment of Sandra Pavez.” 2. Procedure before the Commission. The procedure before the Commission was as follows: a. Petition. On October 28, 2008, the Commission received the initial petition submitted by Sandra Cecilia Pavez Pavez, Rolando Raúl Jiménez Pérez, the legal representative of the Homosexual Integration and Liberation Movement (MOVILH), and Alfredo Morgado (hereinafter “the petitioners”). b. Admissibility Report and Merits Report. On July 21, 2015, and December 7, 2018, the Commission adopted, respectively, Admissibility Report No. 30/15 (hereinafter “the Admissibility Report”) in which it concluded that the petition was admissible, and the Report on the Merits No. 148/18 (hereinafter “the Merits Report”), in which it reached certain conclusions and made several recommendations to the State. c. Notification to the State. On March 11, 2019, the Commission notified the Merits Report to the State and indicated its willingness to assist the parties in reaching a friendly settlement, granting them the regulatory period to present their observations. d. Friendly settlement process. In a brief dated November 7, 2016, the State expressed its willingness to initiate a friendly settlement process. The petitioners did not respond to this request. 3. Submission to the Court. On September 11, 2019, the Commission submitted to the Court all the facts and human rights violations described in the Merits Report, “given the need to obtain justice for the [alleged] victim in this case.” 4. Requests of the Commission. Based on the foregoing, the Inter-American Commission asked the Court to find and declare the international responsibility of the State for the violation of the rights described in the Merits Report and to order the measures of reparation contained in said report. This Court notes, with deep concern that almost eleven years have elapsed between the presentation of the initial petition before the Commission and the submission of the case before the Court. 3