The facts of the case refer to the illegal arrest of Santiago Gómez Palomino on July 9, 1992, and his subsequent forced disappearance, carried out by the armed group “Colina.” Upon his arrest, no reasons were given for his arrest nor was he shown any warrant.

The IA Court developed standards regarding forced disappearance as a violation of multiple human rights, which place victims in a state of complete defenselessness and acquires particular gravity when, as in this case, it forms part of a pattern of applied or tolerated practice by the State. It also established criteria in order for investigations of forced disappearance cases to be carried out with due diligence.