the actual exercise of and protection for trade union freedom.”77 [CHECK QUOTE] Likewise, in its 2002 annual report, MINUGUA pointed to attacks on the right to life and personal liberty of trade unionists.78 It maintained that "action by State institutions to punish these crimes is seen to be limited and provides insufficient safeguards for the exercise of trade union freedom"79. 75. In its final report, in 1999, the Commission for Historical Clarification (CEH) pointed out that during the armed conflict in Guatemala trade union leaders were among the victims.80 The CEH pointed out that, citing the so-called Doctrine of National Security and anti-communism as a pretext and justification, crimes were committed such as the kidnapping and murder of all kinds of trade unionists, all of whom were labeled “subversives”.81 76. Regarding the acts of violence against trade unionists, the CEH had the following to say: In urban areas, diverse human rights violations were committed against trade union members (...) who were directly perpetrated by agents of the State or persons acting with its protection, tolerance or acquiescence and were based on close co-operation between powerful business people and security forces. These acts were committed in order to protect business interests, in accordance with openly anti-trade union government policies. 82 77. In addition, the Inter-American Court deemed it demonstrated in the Case of García and Family v. Guatemala, that trade union organizations "were considered 'internal enemies' in the internal armed conflict in Guatemala."83 It added that during that time "there was a pattern of actions by the State aimed at capturing or eliminating the leaders of unions (...) because they opposed the State’s ideology."84 78. For its part, in the Case of Carlos Gómez v. Guatemala, regarding attacks on a trade unionist in 1993, the IACHR pronounced as follows: [I]t has been and continues to be Government practice in Guatemala to use official agents in acts of repression and clandestine attacks against human rights and union groups.85 79. The ILO's Commission of Inquiry, established to review Guatemala's compliance with the Freedom of Association and Protection of the Right to Organise Convention stated in its 2014 Report that: (...) for several years it, like the Committee on Freedom of Association, has been examining allegations of serious acts of violence against trade union leaders and members of trade unions, and seeing how they have gone unpunished. (...) The Committee observes with profound concern that the allegations are extremely serious and refer to numerous murders 77 MINUGUA, Report on Human Rights, 1998. 78 MINUGUA, Report on Human Rights, September 2000. 79 MINUGUA, Report on Human Rights, September 2000. 80 Commission for Historical Clarification, Guatemala – Memory of Silence, Conclusions and Recommendations, par. 26. 81 Commission for Historical Clarification, Guatemala – Memory of Silence, Conclusions and Recommendations, par. 83. 82 Commission for Historical Clarification, Guatemala – Memory of Silence, Conclusions and Recommendations, par. 146. I/A Court HR. Case of García and Family v. Guatemala. Merits, Reparations, and Costs. Judgment of November 29, 2012, Series C No., par. 118. 83 84 I/A Court HR. Case of García and Family v. Guatemala. Merits, Reparations, and Costs. Judgment of November 29, 2012, Series C No., par. 120. 85 IACHR, Report 29/96, Case 11.303, Merits, Carlos Gómez, October 16, 1996, par. 67. 13