regularly, especially to conduct searches. This is an indication that the National Guard performed regular custodial functions within the prison, and the case file provides no information to indicate the National Guard was properly trained to perform this function, which several inmates stated usually resulted in violence committed by the soldiers during the searches. 61. According to the proven facts, the National Guard entered the Vista Hermosa Prison on the day of the facts under the auspices of Article 8 of the Penitentiary Regimen Act, which provides as follows: External security of the establishments may be entrusted to military bodies, which shall refrain from any intervention in the internal security system, except in cases where expressly requested by the director of the facility or the person acting in that capacity. 62. The Commission finds that this law does not make sufficiently clear the grounds on which the National Guard could be asked to enter a prison, as strict adherence to the primordial duty of protecting the human rights of persons deprived of liberty would require. Furthermore, it grants the director of the facility broad discretion to determine the relevance and necessity of entry into the prison, which, as noted, happened regularly at Vista Hermosa. According to the standards of the inter-American system, the entry of soldiers into a penitentiary should, where permitted, follow criteria of “strict exceptionality” and must be intended only to protect the fundamental rights of the inmates. The Commission finds that the law cited above does not establish safeguards for complying with this standard and creates conditions that make situations like the one in this case possible, as will be analyzed later on. 2. The State’s special status as guarantor for individuals deprived of liberty 63. The settled case law of the inter-American system has established that the State assumes a special position as guarantor of the rights of persons deprived of liberty.124 In consequence, “the State has the obligation to take the necessary measures to protect and ensure the right to life and to personal integrity of those deprived of liberty and to abstain, in any circumstances, from acting in a way that leads to a violation of their life and integrity.”125 64. The Court has established that this obligation includes “the adoption of measures that help maintain a climate of respect for human rights among persons deprived of liberty, avoid the presence of weapons within the establishments in the hands of the inmates, reduce overcrowding, establish the minimum detention conditions compatible with their dignity, and provide sufficient trained staff to ensure an adequate and effective control, custody and surveillance of the Penitentiary Center.”126 65. Along these lines, “whenever a person is deprived of liberty in a normal state of health and later emerges with health issues, the State must provide a satisfactory and convincing explanation for this situation 127 and address allegations of its responsibility with adequate evidence.” 128 Thus, the absence of a satisfactory explanation leads to the presumption of State responsibility for the injuries suffered by a person who has been in the custody of State agents. 129 This is obviously also applicable to situations in which an individual dies while in State custody. See I/A Ct. H.R. Case of Neira Alegría et al. v. Peru. Merits. Judgment of January 19, 1995, para. 60; Case of Díaz Peña v. Venezuela. Judgment of June 26, 2012, para. 135. 125 See, for example, I/A Ct. H.R. Matter of Certain Penitentiary Centers of Venezuela. Central Occidental Region (Uribana Prison) regarding Venezuela. Order of the Inter-American Court of February 13, 2013. Considering 7. 126 Id. 127 I/A Ct. H.R. Case of Mendoza v. Argentina. Judgment of May 14, 2013, para. 203 (citing Case of Juan Humberto Sánchez v. Honduras. Judgment of June 7, 2003, para. 100; Case of Fleury et al. v. Haiti. Judgment of November 23, 2011, para. 77). 128 Id. at para. 203 (citation omitted). 129 I/A Ct. H.R. Case of Mendoza v. Argentina. Judgment of May 14, 2013, para. 203 (citing: Case of the “Street Children” (Villagrán-Morales et al.) v. Guatemala. Merits, paras. 95 and 170; Case of Fleury et al. v. Haiti. Merits and Reparations, para. 77). 124 14