3 6. It is true that the Inter-American Court lacks jurisdiction to determine violations of the Convention on the Prevention and Punishment of the Crime of Genocide (1948). But, two observations are in order. First, Guatemala undertook to protect all the rights embodied in the American Convention as of the date on which it ratified the Convention: May 25, 1978 – prior to the Plan de Sánchez massacre. As I stated in my separate opinion in Case of Blake v. Guatemala (Merits, Judgment of January 24, 1998): “One ought to avoid the confusion between the question of the invocation of the responsibility for compliance with the conventional obligations undertaken by the State Party and the question of the submission of the latter to the jurisdiction of the Court” (para. 34). 7. The jurisdictional issue is distinct from the substantive issue of international responsibility. Even though the Inter-American Court lacks jurisdiction to rule on alleged acts of genocide (which is beyond is competence ratione materiae), this does not exempt the defendant State from its international responsibility – which the State has acknowledged in the instant case – for violation of the rights protected by the American Convention and other humanitarian treaties to which Guatemala is a Party. 8. The State of Guatemala ratified the Convention on the Prevention and Punishment of the Crime of Genocide on January 13, 1950. It also ratified the four 1949 Geneva Conventions on international humanitarian law on May 14, 1952, as well as the two 1977 Additional Protocols to those Conventions on October 19, 1987. The four 1949 Geneva Conventions single out the “grave breaches,”8 and determine, inter alia, the humane treatment of all those affected,9 and respect for the dead.10 The two 1977 Additional Protocols establish “fundamental guarantees.”11 The latter include respect for all human beings, including their “religious practices” and their “convictions” (philosophical or of any other nature).12 Protection is extended to the places of worship, which “constitute the cultural or spiritual heritage of peoples.”13 III. The Principle of Humanity 9. Humane treatment, under any and every circumstance, encompasses all forms of human behavior and all situations of vulnerable human existence. More than an aspect of those guarantees, humane treatment corresponds to the principle of humanity that cuts across the whole corpus juris of both treaty-based and customary international humanitarian law. This consideration leads me to my second 8 Articles 50/51/130/147. 9 Articles 12/12/13/27. 10 Articles 17/20/120/130. 11 Protocol I, Article 75; Protocol II, Articles 4-6. 12 Protocol II, Article 4; cf. commentaries in: Various authors, Commentary on the Additional Protocols of 1977 to the Geneva Conventions of 1949 (eds. Y. Sandoz, Chr. Swinarski and B. Zimmermann), Geneva, Nijhoff/ICRC, 1987, pp. 1368-1381 (commentaries by S. Junod); M. Bothe, K.J. Partsch and W.A. Solf, New Rules for Victims of Armed Conflicts - Commentary on the Two 1977 Protocols Additional to the Geneva Conventions of 1949, The Hague, Nijhoff, 1982, pp. 640-643. 13 Article 53(a) of 1977 Protocol I.