88. Regarding the right to property, the Court has developed a broad definition that covers, among other things, the use and enjoyment of property and rights that can form part of the personal wealth of a person, including personal possessions and real estate, as well as tangible and intangible elements.199 The Court has underscored the particular gravity of, among other things, the theft and/or destruction of items necessary for a community's subsistence and the burning of buildings in the context of an internal armed conflict, especially when they occur as part of acts or threats of violence with the aim of terrorizing the population.200 In such cases, the destruction of homes represents the loss, not only of material possessions, but also of the social frame of reference of the inhabitants and their most basic living conditions, which makes such a violation especially grave.201 89. As regards the right to family life and privacy, the Commission notes that the Court has stated that the sphere of privacy is characterized by being exempt from and immune to abusive and arbitrary invasion or attack by third parties or the public authorities, and therefore that an individual’s home and private life are intrinsically connected, because the home is the space in which private life can evolve freely.202 Furthermore, recognizing the progress made in this regard in international human rights law, the Court has found that in cases such as this, in which the alleged victims who lost their homes also lost the place where there private and family lives unfolded, the State also violates Article 11 (2) of the Convention.203 90. In the instant case, the Commission reiterates that it is accredited that Guatemalan Army personnel invaded the village of Los Josefinos, burned the homes, massacred its inhabitants, went into homes to see if there were any survivors, and murdered those whom they found, including men, women, and children, all as part of a scorched-earth operation designed to completely eradicate the village by destroying and burning homes and possessions and slaughtering its population. 91. Therefore, the Commission concludes that the State of Guatemala violated the right to humane treatment, right to family life and privacy, right to property, and rights of the child recognized in Articles 5 (1), 11 (2), 19, and 21 of the American Convention, in connection with the duty to respect rights established in Article 1 (1) thereof, to the detriment of the residents, families, and children of the village of Los Josefinos, whose homes were burned, invaded, and destroyed, and who are individually identified in the Consolidated Annex on victims to this report on merits. D. Rights to a fair trial204 and judicial protection205 92. As the Court has consistently held: States Parties are obligated to provide effective judicial remedies to the victims of the human rights violations (Article 25), remedies which should be substantiated in conformity with the rules of due process [Article 8(1)], all of this within the general obligation of the same States, to guarantee the free and full exercise of the rights recognized by the Convention for any person under its jurisdiction [Article 1(1)]. I/A Court H.R., Barrios Family Judgment, par. 148. I/A Court H.R., Ituango Massacres Judgment, pars. 178-182; I/A Court H.R., El Mozote Massacres Judgment, par. 179. 201 I/A Court H.R., Ituango Massacres Judgment, par. 182; I/A Court H.R., El Mozote Massacres Judgment, par. 180. 202 I/A Court H.R., Ituango Massacres Judgment, par. 194; I/A Court H.R., El Mozote Massacres Judgment, par. 182. 203 I/A Court H.R., Ituango Massacres Judgment, par. 197 and 234; I/A Court H.R., El Mozote Massacres Judgment, par. 182. 204 The pertinent portions of Article 8 (1) of the American Convention provide: “Article 8. Right to a Fair Trial. 1. Every person has the right to a hearing, with due guarantees and within a reasonable time, by a competent, independent, and impartial tribunal, previously established by law, in the substantiation of any accusation of a criminal nature made against him or for the determination of his rights and obligations of a civil, labor, fiscal, or any other nature.” 205 The pertinent portions of Article 25 (1) of the American Convention provide: “Article 25. Judicial protection. 1. Everyone has the right to simple and prompt recourse, or any other effective recourse, to a competent court or tribunal for protection against acts that violate his fundamental rights recognized by the constitution or laws of the state concerned or by this Convention, even though such violation may have been committed by persons acting in the course of their official duties. 199 200 24