State became aware of them, and for its failure to investigate the attack on Luz Nelly Lima and Jineth
Bedoya in 1999,” again apologizing to Ms. Bedoya and her mother, Luz Nelly Lima. Colombia
recognized that these omissions "violated their rights to dignity, a life plan, personal integrity, judicial
guarantees, and judicial protection, in relation to the obligation to guarantee the rights" enshrined
in the American Convention on Human Rights. Lastly, the State committed to “preventing this type
of situation from recurring and expressed[ed] its willingness to implement additional measures of
reparation to provide compensation for the damage caused to the victims in this case."
21. Additionally, in its final written arguments, the State reiterated the partial recognition of
international responsibility made in the public hearing and accepted that “the judicial system did not
conduct a proper criminal investigation for the victim by collecting 12 statements,” which violated
the rights of Ms. Bedoya “to personal integrity (art. 5), to judicial guarantees (art. 8) and to judicial
protection (art. 25), in relation to the obligation to guarantee the rights enshrined in the American
Convention on Human Rights (art. 1(1)), as well as the duty of due diligence established in article
7(b) of the Convention of Belém do Pará.” The State also acknowledged its international responsibility
“for the failure to comply with the duty of due diligence in the investigation of the threats against
Jineth Bedoya Lima from the moment it became aware of them, and for its failure to investigate the
attack on Luz Nelly Lima and Jineth Bedoya in 1999,” amounting to a violation of the rights of both
victims to honor and dignity (Article 11), personal integrity (Article 5), judicial guarantees (Article
8), and judicial protection (Article 25), in relation to the obligation to guarantee the rights enshrined
in the American Convention on Human Rights (Article 1(1)). Lastly, the State also recognized its
responsibility for the violation of articles 1, 6, and 8 of the ICPPT as a result of "lack of due diligence
in the investigation of the threats against journalist Jineth Bedoya."
22. The Commission "took note" of the partial acknowledgment of international responsibility
made by the Colombian State at the hearing and described it as "a positive contribution to the process
of affirmation of the victims.” However, it recalled that the recognition of international responsibility
"must be comprehensive," and that a dispute persists over "essential aspects of the case," such as
"the State’s responsibility for the events that occurred on May 25, 2000."
23. The representatives described the State’s recognition of international responsibility as
“regrettable ... in view of the seriousness of the violations that took place in this case." They also
described the recognition as “very limited” and noted that there were “multiple other violations of
due process and access to justice” alleged in the framework of this case.
B.
Considerations of the Court
24. Pursuant to Articles 62 and 64 of the Rules of Procedure, and in exercise of its authority in
relation to the international protection of human rights, a matter of international law, the Court must
ensure that acts of recognition of responsibility are acceptable for the purposes pursued by the interAmerican system. 26 The Court will now proceed to analyze the situation in this specific case.
b.1 Regarding the facts
25. In the instant case, the State raised two specific issues in its partial acknowledgment, namely
(i) a specific deficiency in the investigation of the facts that took place on May 25, 2000—that is, the
excessive collection of 12 statements from Ms. Bedoya, and (ii) the lack of due diligence in
Cf. Case of Manuel Cepeda Vargas v. Colombia. Preliminary Objections, Merits, Reparations and Costs. Judgment
dated May 26, 2010. Series C No. 213, para. 17; and Case of Grijalva Good v. Ecuador. Preliminary Objections, Merits,
Reparations and Costs. Judgment of June 3, 2021. Series C No. 426, para. 31.
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