8. 9. environmental rights based on Article 26 of the Convention, understanding that they would be justiciable individually.4 As I have mentioned in previous concurring opinions and reiterating the arguments presented in them,5 I adhere to a different position, which I have called “the thesis of indivisibility-simultaneity” which is based on the universality, indivisibility, interdependence and interrelationship of the human rights, to maintain that the Court has competence to examine violations of the economic, social, cultural and environmental rights. And this is due to the conviction that human rights are interdependent and indivisible so that the civil and political rights are interwoven with the economic, social, cultural and environmental rights. This interdependence and indivisibility allow the individual to be observed integrally as the titleholder of all rights. If he/she is not seen in this way, the rights and human dignity would be artificially fragmented. A similar perspective is asserted in the Preamble to the Protocol of San Salvador: “Considering the close relationship that exists between economic, social and cultural rights, and civil and political rights, in that the different categories of rights constitute an indivisible whole based on the recognition of the dignity of the human person, for which reason both require permanent protection and promotion if they are to be fully realized, and the violation of some rights in favor of the realization of others can never be justified.” 10. In this perspective, Article 26 of the Convention functions as a framework article, in the understanding that it makes a general reference to the economic, social, cultural and environmental rights, and refers us to the OAS Charter for their description and determination. The Protocol of San Salvador individualizes and provides content to the economic, social, cultural and environmental rights, explaining that cases related to trade union rights and education are justiciable before the Court by means of individual petitions (Art. 19(6)). The Protocol mentions that it is essential that those rights be reaffirmed, developed, perfected and protected (see Preamble). Finally, a series of instruments of the inter-American corpus juris also refer to the ESCER. 11. I have already underlined the importance of Article 4 of the Protocol of San Salvador insofar as it does not admit restrictions of the ESCER. Article 4 of the Protocol of San 4 Cf. Case of Lagos del Campo v. Peru. Preliminary objections, merits, reparations and costs. Judgment of August 31, 2017. Series C No. 340, paras. 142 and 154; Case of the Discharged Employees of PetroPeru et al. v. Peru. Preliminary objections, merits, reparations and costs. Judgment of November 23, 2017. Series C No. 344, para. 192; Case of San Miguel Sosa et al. v. Venezuela. Merits, reparations and costs. Judgment of February 8, 2018. Series C No. 348, para. 220; Case of Poblete Vilches et al. v. Chile. Merits, reparations and costs. Judgment of March 8, 2018. Series C No. 349, para. 100; Case of Cuscul Pivaral et al. v. Guatemala. Preliminary objection, merits, reparations and costs. Judgment of August 23, 2018. Series C No. 359, paras. 75 to 97; Case of Muelle Flores v. Peru. Preliminary objections, merits, reparations and costs. Judgment of March 6, 2019. Series C No. 375, paras. 34 to 37; Case of the National Association of Discharged and Retired Employees of the National Tax Administration Superintendence (ANCEJUB-SUNAT) v. Peru. Preliminary objections, merits, reparations and costs. Judgment of November 21, 2019. Series C No. 394, paras. 33 and 34; Case of Hernández v. Argentina. Preliminary objection, merits, reparations and costs. Judgment of November 22, 2019. Series C No. 395, para. 62, and Case of the Indigenous Communities of the Lhaka Honhat (Our Land) Association v. Argentina. Merits, reparations and costs. Judgment of February 6, 2020. Series C No. 400, para. 195. 5 Cf. Concurring opinion to the judgment of November 21, 2019, in the Case of the National Association of Discharged and Retired Employees of the National Tax Administration Superintendence (ANCEJUB-SUNAT) v. Peru. and to the judgment of November 22, 2019, in the Case of Hernández v. Argentina; Case of the Indigenous Communities of the Lhaka Honhat (Our Land) Association v. Argentina, and Case of the Workers of the Fireworks Factory of Santo Antônio de Jesus and their families v. Brazil.