26. The State argued that the representatives bypassed the procedure established in Articles 46 to 51 of the Convention, because they presented, for the first time, before the Court arguments and violations of the Convention that were not indicated opportunely before the Commission, namely: the allegedly violations of Articles 9 and 2 of the Convention. It argued that this prevented the State from exercising the defense mechanisms established in Articles 46(2) and 47 of the Convention, which resulted in a violation of due process and its right of defense, so that the Court lacks competence to examine these new requests by the representatives. 27. The Commission observed that the legal classification made by the representatives was based on the factual framework of its Merits Report as regards the normative applicable to the deportation procedure. In addition, it considered that, in keeping with the regulation of the system of individual petitions in the American Convention,29 the fact that a petitioner does not allege a specific violation under an article of the American Convention in the proceedings before the Commission, “does not, in itself, result in a limitation to making autonomous legal arguments that differ from those of the Commission in the proceedings before the Court, and having legal representation.” 28. The representatives indicated that the State’s position was unclear, but inferring that the supposed new facts to which the State is referring are those related to the violation of Articles 9 and 2 of the Convention, these facts do not modify, alter or impair the factual framework of the case. Considerations of the Court 29. The Court notes that the legal classification of certain facts under Articles 9 and 2 of the Convention, proposed by the representatives, is based on the factual framework of this case. In particular as regards the normative applicable to the domestic procedures for the deportation of a person owing to his or her migratory situation and for the determination of refugee status. Thus, as indicated in the preceding segment (supra paras. 23 and 24), the Court is able to examine the alleged violation of these provisions, without the exhaustion of domestic remedies – which, in any case, the State did not provide grounds for – being relevant in this regard. Consequently, the Court determines that the State’s assertion is not a matter for a preliminary objection, so that it is inadmissible. C. “Competence ratione loci” Arguments of the parties and of the Commission 30. The State argued that the representatives had attributed to Bolivia facts that had occurred outside its territory, in relation to the alleged violation of Article 17 of the Convention, owing to the separation of the Pacheco Tineo family and the consequences of a pecuniary and non-pecuniary nature that they had faced or suffered as of their first detention in Peru.30 It indicated that the Court had already declared Mr. Pacheco Osco and Mrs. Tineo Godos to be 29 It considered that the lodging of a petition does not require legal representation and that a detailed description of the actions that are considered to have violated the Convention was sufficient, as well as adequate information to issue a ruling on whether the admissibility requirements had been met. Throughout the proceedings before the Commission, the procedures should respond to the different levels of representation or experience of the petitioners and, if pertinent, of their representatives. It is the Inter-American Commission that must, based on its attributes, make a legal classification of the facts described by the petitioners in its Admissibility Report, at that time defining the purpose of the case, which will be analyzed at the merits stage. 30 It indicated that the representatives referred to facts such as the separation of the family, the psychological traumas, and the physical ailments, the attacks on the reputation of the family members, and the harm to their life projects, much of which resulted from the torture, detention, persecution, and other wrongful acts that supposedly occurred in Peru. 12