girls “were subjected to many human rights violations, and were direct victims of forced disappearance, arbitrary execution, torture, abduction, rape, and other acts that violated their fundamental rights.”28 20. Finally, the Court has consistently held that forced disappearance in Guatemala constituted a practice of the State during the time of the internal armed conflict. 29 Such forced disappearances were carried out mainly by agents of the security forces: “[M]embers of insurgent movements or people identified as inclined to insurgency were captured and held secretly without informing a competent, independent, and impartial legal authority, and they were physically and psychologically tortured in order to obtain information and, possibly, even murdered.”30 The purpose was to dismantle movements or organizations that the State deemed inclined toward insurgency and to spread terror throughout the population.31 21. In light of the foregoing and of all the evidence that it has seen in this particular case, the Commission considers that the Guatemalan Army's raid on the village of Los Josefinos in Petén Department on April 29 and 30, 1982, was carried out in the context of the internal armed conflict, in which there was a State policy of perpetrating massacres, scorched-earth operations, and forced disappearances with the aim of wiping out entire families and destroying the community. That context constituted a generalized and systematic attack, with massive human rights violations on the part of the State against the civilian population. B. The alleged victims 22. The Commission notes that in their concluding observations on merits, the petitioners referred to serious difficulties in identifying all the victims—not only the deceased, but also their surviving and displaced relatives. Among those difficulties, the petitioners mentioned the violence used by the Army during the massacre and subsequent displacement, as well as the fact that, because the majority of the homesteads and houses in the village were set on fire, many people burnt to death, making it impossible later to identify their remains. Furthermore, in spite of the analysis of the 19 skeletons recovered from the mass grave, owing to the lack of direct information from close relatives and the eroded states of the bone remains, even with DNA tests it was only possible to accurately identify one of the victims of the massacre. It is also necessary to take into account the rural context in which life at Los Josefinos went on at the time of the events, with high rates of illiteracy and a lack of official birth and death records. That would explain why relatives do not have documentation on the deceased, either because individuals are registered in a slightly different way or because there are no official records certifying the identities of everyone living in Los Josefinos at the time of the massacre. 23. In addition to the foregoing, various acts and omissions on the part of the State have created added obstacles that prevent identification of all the victims. Notably, the fact that it took 14 years before the investigation began and the remains were exhumed; the lack of sufficient efforts to identify the victims, despite numerous statements by survivors; the large number of irregularities in the chain of custody and conservation of evidence recovered; and the well-founded fear on the part of some survivors of identifying their relatives, given the disturbing pattern of persecution and impunity in Guatemala. 24. The Commission acknowledges that it is incumbent upon it to identify precisely the alleged victims in a case when pronouncing on its merits. 32 However, there are certain circumstances in which, “taking into account [the] magnitude [of the case], the nature of the facts, and the time that has passed ... it [is] reasonable that the identification and individualization of each presumed victims [Tr: sic] is complex,” although there must I/A Court H.R., Molina Theissen Judgment, par. 40.6. I/A Court H.R., Tiu Tojín Judgment, par. 49; I/A Court H.R., Chitay Nech Judgment, par. 67; I/A Court H.R., Río Negro Massacres Judgment, par. 117 and footnote 56; I/A Court H.R., García and Family Judgment, par. 54; I/A Court H.R., Molina Theissen Judgment, par. 40.1. 30 I/A Court H.R., Tiu Tojín Judgment, par. 49. See also I/A Court H.R., Chitay Nech Judgment, par. 67; I/A Court H.R., Río Negro Massacres Judgment, par. 117 and footnote 56; I/A Court H.R., García and Family Judgment, par. 54. 31 CEH, Guatemala: Memory of Silence, Conclusions and Recommendations, p. 44. 32 I/A Court H.R., Case of the Ituango Massacres v. Colombia, Judgment of November 29, 2006, Series C No. 148 (hereinafter “I/A Court H.R., Ituango Massacres Judgment”), par. 98. See also I/A Court H.R., Río Negro Massacres Judgment, par. 20; I/A Court H.R., Tiu Tojín Judgment, par. 58. 28 29 6