312. The representatives asked the Court to order the State to “produce audiovisual material (film or documentary) that reconstructs the facts of the case, in consultation with the victims and their representatives, and in accordance with the Court’s Judgment.” They also indicated that compliance with the measure would be part “of a public campaign that highlights the civilian population status of the victims of the massacre and counters the stigmatization [to which] they were subjected as supposed members of the guerrilla or collaborators with the insurgency.”444 The Commission did not present specific arguments with regard to this measure of reparation. The State referred, in general, to article 149 of Law 1448 of 2011 (Victims Act) and indicated that it had adopted legal, administrative and other measures to avoid the repetition of the facts, including verification of the facts and the complete public dissemination of the truth, insofar as this did not cause more unnecessary harm to the victims, the witnesses or other persons, or create any danger to their safety. 313. Regarding this request, the Court recalls that it has not found that the alleged violation of the right to honor of the victims of the events of Santo Domingo has been proved; therefore, it does not find it pertinent to order the measure requested. 314. The representatives asked the Court to order the State to guarantee the life and personal integrity of all those victims who have been taken part in the processing of the proceedings and, subsequently, in the judgment delivered by the Court. They added, “[s]pecifically as regards guarantees for participation in the criminal proceedings, taking into account the murder of Ángel Trifilo (witness to the massacre and the subsequent events), as well as the facts that the Court was advised of by the representatives in a communication of May 30, 2012, related to pressure and harassment against the victims of Santo Domingo.” 315. The Court considers that no arguments or evidence was forwarded that supports the representatives’ request, so that it is not appropriate to order this measure of reparation. 316. The Commission asked the Court to order the State to “adopt such measures as may be necessary to prevent a repetition of patterns of violence against the civilian population in keeping with the duty to protect and ensure the fundamental rights recognized in the American Convention. The representatives considered that the State “must adopt […] the necessary legislative, administrative and other measures to guarantee, effectively, the non-repetition of events such as those that occurred in this case.”445 As part of this process, it must ensure that the laws regarding the disproportionate use of force and use of weapons ensure the highest possible level of protection for the citizenry.”446 The State did not present specific arguments in this regard. 317. Regarding the measure of reparation requested, the Court observes that, in the instant case, it had not been proved that the alleged shortcomings in domestic law had resulted in noncompliance with the obligation to adopt provisions of domestic law contained in Article 2 of the 444 In addition, they stated that this material “should be transmitted, in keeping with the authority of the National Television Commission, by public and private channels at peak time, and used in the training courses for the Military Forces, as a means of counteracting the judicial and extrajudicial public defamation of the victims carried out by members of the Military Forces by the preparation of the video La Verdad sobre Santo Domingo, and its dissemination on several television programs and television news programs. 445 In particular, they asked the Court “to order Colombia to undertake the necessary legal, administrative and other measures to avoid the repetition of similar events, not only in relation to the Colombian Armed Forces, but also, as a priority, it should adopt preventive measures in relation to the activities of foreign security and surveillance companies and extractive companies on Colombian territory, precisely to prevent possible human rights violations.” 446 They asked, in particular, for the incorporation of protocols, guidelines and laws for the protection of the civilian population and their property in accordance with humanitarian law for the conduct of hostilities, in the design, planning and execution of counterinsurgency airborne operations, as well as control mechanisms to avoid the repetition of similar events to those that occurred in the massacre of Santo Domingo. They also asked the Court to order the State: (a) to abstain from using procedural obstacles such as the expiry of time frames, prescription, res judicata, the principle of non bis in idem, amnesty laws or any other mechanism tending to exempt those who took part in the events of responsibility. In particular, those related to the constitutional reform known as the “legal framework for peace,” and (b) “to remove immediately the de facto and de jure procedural obstacles generated during the proceedings before the military criminal justice system, adapting the necessary normative, practical and jurisprudential mechanisms to ensure that all those responsible are investigated, prosecuted and punished proportionately.” Lastly, it asked the State to prohibit members of the Military Forces accused of severe human rights violations from continuing to fail to serve their sentences on military premises.” ‐ 89 ‐    

Select target paragraph3