Armed Force” that, it considered, fulfilled its obligation to provide training on human
rights to the National Armed Forces.
27.
The representatives appreciated the information presented by the State regarding
the human rights and international humanitarian law programs. However, they observed
that compliance with this aspect “is not achieved merely by providing this academic
information,” because compliance required continuous training and education activities
on human rights, and these “are not specified, […] and neither are the number of military
or police officials who have taken these courses and the follow-up evaluations”;
accordingly, they asked the Court to require information in this regard.
28.
The Commission merely noted that it “appreciate[d] the information provided by
the State.”
29.
The Court recalls that human rights education within the security forces is crucial
for ensuring the non-repetition of events16 such as those of the present case
Consequently, the Court takes note of the information provided and appreciates the
creation of the “Program of Human Rights and International Humanitarian Law Courses
for Educational Establishments of the Bolivarian National Armed Forces” of the Vice
Ministry for Education of the Armed Forces, of the Ministry of the People’s Power for
Defense. However, the information presented by the State reveals that the issues of the
prohibition of forced disappearance, torture and the disproportionate use of force, taking
into account the case law of the inter-American system for the protection of human
rights, are not included in the academic programs of all the Armed Forces schools.
Consequently, the Court finds that the State must take the necessary steps, as soon as
possible, to incorporate these issues into the curriculum. When submitting information on
this aspect, the State must indicate the parts of the training and education courses based
on which it is complying with this obligation.
30.
Furthermore, according to the judgment (supra having seen paragraph 1), this
measure of reparation also refers to training courses for officials of the “Intelligence and
Prevention Services Sectoral General Directorate” and the State did not specifically
address this aspect of the reparation. Therefore, the Court finds it essential that the
State submit recent detailed and complete information on the courses for intelligence
service officials.
31.
In summary, having verified the schools it encompasses, as well the curriculum,
objectives and content of the “Program of Human Rights and International Humanitarian
Law Courses for Educational Establishments of the Bolivarian National Armed Forces” of
the Vice Ministry for Education of the Armed Forces, of the Ministry of the People’s Power
for Defense, the Court considers that the State has complied partially with this obligation,
as regards implementation of a program for the Armed Forces on the principles and
norms for the protection of human rights.
g) Regarding the obligation to pay the amounts established in the judgment
(thirteenth, fourteenth and fifteenth operative paragraphs of the judgment)
32.
The State reported that it was taking the necessary steps as regards budgetary
planning in order to make the said payments, since it “intended to include the
16
Cf. Case of Goiburú et al. v. Paraguay. Monitoring compliance with judgment. Order of the InterAmerican Court of Human Rights of November 19, 2009, forty-ninth considering paragraph, and Case of
Zambrano Vélez et al. v. Ecuador. Monitoring compliance with judgment. Order of the Inter-American Court of
Human Rights of September 21, 2009, sixty-second considering paragraph.
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