special rights by virtue of their status as children,153 considering their particularly vulnerable condition.154 To safeguard those rights special protection measures must be adopted, 155 based on the principle of the best interests of the child,156 which should be determined based on the needs of the child as “a true legal person, and not just as an object of protection.157 57. According to the established facts in the case, on the morning of April 29, 1982, armed guerrillas entered Los Josefinos and captured and murdered two individuals: one because of his supposed links to the Army, the other for being a military commissioner. After a clash with the guerrillas in the afternoon of that day, the Guatemalan Army surrounded the village to prevent any of its inhabitants from leaving and then proceeded to enter it after midnight on April 30, 1982. First they killed at least five patrol members who were on the street. Then, the soldiers started setting fire to homes and extrajudicially executing anyone they found inside them; the victims were all defenseless civilians. Of the victims, so far it has been possible to identify 4 women, 18 men, and 14 children. 58. In addition, the Commission reiterates that two very young children died during the escape for lack of food; for the reasons given above, the IACHR considers them also to be victims of the massacre. Furthermore, according to the established facts, since the date of the massacre the whereabouts of at least eight people, including two minors, are unknown. With respect to the latter group, bearing in mind that they were all in the village at the time of the massacre, that they are still unaccounted for, the time that has elapsed, and that the State included several of them in its compensation arrangements for victims killed in the massacre, the IACHR presumes that they too are all deceased. 59. Likewise, it has been demonstrated that before being extrajudicially executed the victims were subjected to acts that harmed their physical and mental integrity. This conclusion is consistent with the findings of the CEH, which documented the fact that one common characteristic of most massacres, “in addition to executions, is the amassing of serious human rights violations such as torture, cruel treatment (…) and aberrant acts such as mutilation of corpses.”158 By the same token, the various declarations contained in the judicial case file and in the record in the possession of the IACHR, as well as the expert findings of the Forensic Anthropology Foundation of Guatemala, attest to the brutality with which the residents of the village of Los Josefinos were extrajudicially executed. 60. The Commission considers it necessary also to set down for the record that this is particularly egregious case, not just because the victims were utterly defenseless when the Army soldiers executed them in barbaric acts, but also because the massacre, executions and disappearances of these people were not isolated events within Guatemala’s internal armed conflict, but rather part of a State policy based on the so-called “National Security Doctrine” and the notion of an enemy within, whose aim was to eliminate the supposed social base of insurgent groups at the time.159 Thus, the massacre in this case was framed by a context of special operations planned and carried out by state agents within a framework of systematic persecution of anyone perceived as being opposed to the established order. 2, 2004, Series C. No. 112 (hereinafter “I/A Court H.R., Juvenile Reeducation Institute Judgment”), par. 147; I/A Court H.R., Case of Servellón García et al. v. Honduras. Judgment of September 21, 2006, Series C. No. 152. par. 113. 153 I/A Court H.R., Las Dos Erres Massacre Judgment, par. 184. 154 I/A Court H.R., Advisory Opinion, Juridical Condition and Human Rights of the Child, par. 54. 155 I/A Court H.R., Advisory Opinion, Juridical Condition and Human Rights of the Child, par. 62; I/A Court H.R., Juvenile Reeducation Institute Judgment, par. 147; I/A Court H.R., Ituango Massacres Judgment, par. 244; I/A Court H.R., Mapiripán Massacre Judgment, par. 152; I/A Court H.R., Las Dos Erres Massacre Judgment, par. 184. 156 I/A Court H.R., Ituango Massacres Judgment, par. 244; I/A Court H.R., Mapiripán Massacre Judgment, par. 154. 157 I/A Court H.R., Advisory Opinion, Juridical Condition and Human Rights of the Child, par. 28. 158 CEH, Memory of Silence, par. 3057. 159 CEH, Memory of Silence, pars. 3083-3084: “The figures [626 massacres] reveal the magnitude of the massacre phenomenon in the Army’s military operations to annihilate the enemy within. In applying the counterinsurgency strategy, hundreds of communities in different parts of Guatemala became the victims of the scorched-earth policy during the armed conflict. The methods used during these collective executions demonstrate the degree of cruelty unleashed upon the victims, all of whom were defenseless and unarmed. […] And yet, the impact of the massacres cannot be grasped by just looking at the figures; instead, a qualitative analysis of this merciless violence is needed in order to discover the underlying logic of the military’s strategies and tactics and the horror that they meant for the victim populations.” 17