- 30 - 81. The violence against the UP has been characterized as systematic by both national and international organizations, given the intent to attack and eliminate its representatives, members and even sympathizers. The United Nations High Commissioner for Human Rights referred to the executions perpetrated against the UP as “systematic”;97 while the Ombudsman called the violence against this party “systematized extermination”;98 the Constitutional Court of Colombia called it “progressive elimination”;99 the Inter-American Commission “massive and systematic assassination”;100 the office of the Attorney General of the Nation referred to “systematic extermination,”101 and the National Commission for Reparation and Reconciliation to “extermination.”102 82. According to the Ombudsman, the failure of the National Government and the FARC to abide by the peace agreements103 was decisive in generating the violence against the UP, inasmuch as it was not granted the necessary guarantees and security to enable it to carry out its political activities.104 Above all, the violence was related to the identification of the UP with the FARC.105 97 Report of the United Nations High Commissioner for Human Rights on the Office in Colombia, supra note 86, folio 3331. 98 Report of the Ombudsman entitled “Estudio de casos de homicidio de miembros de la Unión Patriótica y Esperanza, Paz y Libertad,” supra note 76, folio 1215. 99 Judgment delivered by the Second Review Chamber of the Constitutional Court in case No. T-439, supra note 93, folio 1367. 100 Inter-American Commission on Human Rights, Second report on the situation of human rights in Colombia, supra note 83, folio 3551. The Commission presented the violations against the UP as an example of “acts of genocide” in Colombia. 101 Opinion of the office of the Attorney General of the Republic on the legality of the second instance judgment in relation to investigation No. 18,428, dated May 7, 2004 (evidence file, tome IV, attachment 32 to the application, folio 1802). 102 National Reparation and Reconciliation Commission, first report on the historical memory entitled “Trujillo, una tragedia que no cesa” [Trujillo, an ongoing tragedy], Editorial Planeta, Bogotá, Colombia, September 2008 (evidence file, tome XII, attachment 184 to the brief with pleadings, motions and evidence, folio 5564). 103 Expert witness Eduardo Cifuentes stated that “[i]n 1986, when the new President of the Republic, Virgilio Barco Vargas, took office, there was an evident retreat from compliance with the agreements made under the peace process between the FARC-EP and the National Government. There was, on the one hand, an absence of progress in the implementation of structural changes in the institutional framework, except for the approval of the law that allowed mayors to be elected by popular vote and, on the other, FARC violations of the cease fire and its military expansion over a very short span of time.” Opinion provided before notary public (affidavit) by expert witness Eduardo Cifuentes Muñoz, supra note 77, folio 8346. 104 Cf. Report of the Ombudsman entitled “Estudio de casos de homicidio de miembros de la Unión Patriótica y Esperanza, Paz y Libertad,” supra note 76, folios 1217 to 1218. Similarly, the first report of the National Reparation and Reconciliation Commission states that “[t]he reticence of some national political, ecclesiastical and trade union sectors towards the Betancur peace process, together with the opposition of local and regional authorities as well as some sectors of the Army and the Police to the Patriotic Union’s political progress, undermined this process. These tensions were revealed by the failed attempt to grant legality to the most political sectors of the armed groups and the Communist Party, which resulted in the massacre of many of their members.” First report on the historical memory entitled “Trujillo, una tragedia que no cesa”, supra note 102, folio 5563. 105 Cf. First report on the historical memory entitled “Trujillo, una tragedia que no cesa”, supra note 102, folio 5564. The report indicates that “[t]his extermination [of the UP], starting in 1986, was based on the premise that Patriotic Union was the political arm of the FARC in order to legitimate a counterinsurgency operation that went beyond the combatants and extended to the political parties and movements that were considered to have links to the guerrilla.” Also, the Constitutional Court observed that “[t]he formal or simply word-of-mouth connection with the Patriotic Union, in the context of the ideological and political persecution unleashed against its members or those who sympathized with it, is a determinant factor in the case.” Judgment delivered by the Second Review Chamber of the Constitutional Court in case No. T-439, supra note 93, folio 1368. Expert witnesses Andreu and Cifuentes were of the same opinion. Cf. Opinion provided before notary public (affidavit) by expert witness Federico Andreu Guzmán, supra note 83, folio 8323 and opinion provided before notary public (affidavit) by expert witness Eduardo Cifuentes Muñoz, supra note 77, folio 8354.