end, the State cannot rely on the defense that the complainant has failed to present evidence when it cannot be obtained without the State's cooperation.110 Moreover, given the nature of forced disappearance, which is committed with the intention of concealing what has occurred, circumstantial evidence, indicia, and presumptions of the commission of a crime are especially important, inasmuch as, taken as a whole, they make it possible to draw conclusions consistent with the facts.111 86. This Court has also held that, in some cases, the analysis of forced disappearance based on the three elements mentioned may be insufficient or unnecessary. This happens, for example, when the disappearance affects individuals over whom the State has a special position of guarantor, such as that held with respect to individuals deprived of their liberty.112 Thus, in the case of Isaza Uribe et al. v. Colombia, the Court considered that, just as it happens when the State does not provide a satisfactory explanation about the injuries suffered by a person deprived of his or her liberty, the State's responsibility can also be presumed when the person disappears while under its custody without it disproving the allegations about state responsibility.113 Such conclusion arises as a corollary of the State's objective responsibility regarding the life, integrity, and safety of the individuals under its custody.114 In such circumstances, regardless of the individual responsibilities that the authorities may need to determine within their respective scopes of authority, it is possible that forms of forced disappearance may occur due to the omission of state agents who were supposed to ensure the guarantee of rights, regardless of whether there is also evidence of direct participation or other forms of acquiescence.115 87. As such, when there is suspicion that a person has been subjected to forced disappearance, the State has the obligation to provide an immediate, satisfactory, and convincing explanation of what happened to a person who was under State custody,116 which is naturally linked to the State's obligation to conduct a serious and diligent investigation into the matter.117 For this reason, this Court’s case law has considered that the State's failure to clarify the facts is a sufficient and reasonable element to lend weight to the evidence and belief that a forced disappearance was Cf. Case of Velásquez Rodríguez v. Honduras, supra, para. 135, and Case of Movilla Galarcio et al. v. Colombia, supra, para. 122. 111 Cf. Case of Velásquez Rodríguez v. Honduras, supra, paras. 130 and 131, and Case of Members and Militants of the Patriotic Union v. Colombia, supra, para. 271. 112 Cf. Case of Isaza Uribe et al. v. Colombia, supra, para. 92. 113 Cf. Case of Isaza Uribe et al. v. Colombia, supra, para. 88 to 95. 114 Cf. Case of Isaza Uribe et al. v. Colombia, supra, para. 89. 115 Cf. Case of Isaza Uribe et al. v. Colombia, supra, para. 92. 116 Cf. Case of Isaza Uribe et al. v. Colombia, supra, para. 93. See, mutatis mutandi: Case of Juan Humberto Sánchez v. Honduras. Preliminary Objection, Merits, Reparations, and Costs. Judgment of June 7, 2003. Series C No. 99, para. 111; Case of Chinchilla Sandoval et al. v. Guatemala. Preliminary Objection, Merits, Reparations, and Costs. Judgment of February 29, 2016. Series C No. 312, para. 257; Case of Munárriz Escobar et al. v. Peru. Preliminary Objection, Merits, Reparations, and Costs. Judgment of August 20, 2018. Series C No. 355, para. 73, and Case of Guachalá Chimbo et al. v. Ecuador. Merits, Reparations, and Costs. Judgment of March 26, 2021. Series C No. 423, para. 163. 117 Cf. Case of Anzualdo Castro v. Peru, supra, para. 65, and Case of Isaza Uribe et al. v. Colombia, supra, para. 93. Likewise, see Article 12(2) of the International Convention for the Protection of All Persons from Enforced Disappearance and 13 of the Declaration on the Protection of all Persons from Enforced Disappearance. In addition, the Vienna Declaration and Programme of Action approved by the World Conference on Human Rights on June 25, 1993, established that: "it is the obligation of all States, in any circumstances, to undertake an investigation whenever there are grounds to believe that a forced disappearance has occurred in a territory subject to their jurisdiction and, if the arguments are confirmed, to prosecute the perpetrators of the act" (para. 62). Cf. Case of Isaza Uribe et al. v. Colombia, supra, note 99. 110 -26-