26. Moreover, as indicated above, the arguments substantiating the preliminary objection that the State submitted to the Commission during the admissibility stage should match those brought before the Court.30 The Court finds that the State, in its answering brief, in the public hearing, and in its final arguments, did bring arguments consistent with those made before the InterAmerican Commission. 27. Nonetheless, the Court deems that, in the first place, the discussion on whether the applicants performed all the procedural activities necessary to push forward the enforcement of the judgment, and second, the examination of the alleged unjustified delay in enforcement of the judgment, will require an evaluation of the State’s actions regarding its obligations to respect and guarantee the rights recognized in the American Convention that are claimed to have been violated, and this is a matter intimately associated with the merits of the action.31 The Court therefore holds that this argument by the State cannot be examined as a preliminary consideration and must be considered together with the merits. The Court therefore denies the preliminary objection brought by the State. V PRELIMINARY QUESTIONS 28. The State raised two preliminary questions in its answering brief regarding the parameters of the factual framework and the treatment of the judgments as pension-related debts. The Court will examine both points together. A. Arguments by the State and observations of the Commission and the representatives 29. The State argued that the Commission and the representatives had clearly circumscribed the cause of action to the alleged failure to enforce final, non-appealable judgments. Nonetheless, the Commission in its Merits Report, and the representatives in their pleadings and motions brief, submitted evidence and arguments regarding the “historical debt” that was created when teaching staff from the Ministry of Education were transferred to the municipalities in the 1980s. The State explained, then, that the so-called “historical debt” “is clearly different in nature from the debt initiated by the thirteen specific judicial verdicts for a particular group of teachers,” and therefore it felt that the “historical debt” lay outside the corpus of facts and asked that this be clarified and that all evidence and arguments on this point be disallowed. The State also argued that the Commission’s portrayal of the judgments as pension-related debts in the Merits Report was not only incorrect, but lay outside the corpus of facts. 30. The Commission emphasized in its closing observations that the payments derived from the judgments were clearly for pensions, but did not explicitly give an opinion on the State’s arguments about circumscribing the factual framework. The representatives similarly emphasized that the debt was for retirement programs, as it was part of the compensation that the teachers should have received. They did not expressly address the parameters of the corpus of facts. 30 Cf. Case of Furlán and family v. Argentina, supra, para. 29, and Case of Vera Rojas et al. v. Chile, supra, para. 22. 31 Cf. Case of Velásquez Rodríguez v. Honduras. Preliminary objections, supra, para. 96, and Case of Azul Rojas Marín et al. v. Peru. Preliminary Objections, Merits, Reparations and Costs. Judgment of March 12, 2020. Series C No. 402, para. 26. 11