65 2.5.5. Right to property (Article 21 of the American Convention, read in conjunction with Article 1(1) thereof) 282. The case law of the Court has developed a broad concept of property that includes, inter alia, the use and enjoyment of property, defined as those material objects that may be appropriated, and also any right that may form part of a person’s patrimony.368 The Court has found a violation of the right to private property in cases in which the State was deemed responsible for the destruction of houses and other property.369 283. The CEH found that in most cases, “the massacres involved pillaging of the victims’ possessions and the destruction of their homes, crops, animals, cooking utensils, grinding stones, clothing, and anything they had for their material survival, all part of the so-called scorched-earth operations.”370 It also made the point that: Irrespective of the actions, a considerable percentage of massacres recorded by the CEH had other features suggesting that the purpose was to eliminate the communities’ basic means of subsistence, cause the communities to break up or destroy them altogether, and to dismantle their organizations and other mechanisms of collective endeavor. The most important elements in this respect were: the physical destruction of the communities, the homes, crops and animals, places of prayer, schools, communal meeting rooms, and other community buildings; the desecration of the churches by using them as places for torture and execution; destruction of material elements like corn and grinding stones, which carry strong symbolism for the culture 371 [.] 284. In the present case, it has been established that members of the Army, after perpetrating the various massacres and executions against the village of Chichupac and neighboring communities, not only stole the personal effects, food and domestic animals belonging to the villagers, but also destroyed the goods and, in some cases, burned down all the homes. According to the 372 petitioners, between 100 and 125 homes were destroyed. 285. For the foregoing reasons, the Commission concludes that there are sufficient elements to find that the Guatemalan State violated Article 21 of the American Convention, read in conjunction with Article 1(1) thereof, to the detriment of the members of the village of Chichupac and neighboring communities. 2.6. Rights to a fair trial and to judicial protection (articles 8 and 25 of the American Convention read in conjunction with Article 1(1) thereof) 368 I/A Court H.R., Case of Ivcher Bronstein v. Peru. Merits, Reparations and Costs. Judgment of February 6, 2001. Series C No. 74, par.122; Case of the Barrios Family v. Venezuela. Merits, Reparations and Costs. Judgment of November 24, 2011. Series C No. 237, par.148. 369 I/A Court H.R., Case of the Ituango Massacres v. Colombia. Preliminary Objection, Merits, Reparations and Costs. Judgment of July 1, 2006. Series C No. 148; Case of the Massacres of El Mozote and Nearby Places v. El Salvador. Merits, Reparations and Costs. Judgment of October 25, 2012. Series C No. 252, par.168. 370 Annex 3. CEH, Memory of Silence, Volume III, The Human Rights Violations and Acts of Violence, par.3054. 371 Annex 3. CEH, Memory of Silence, Volume III, The Human Rights Violations and Acts of Violence, par.3076. 372 Annex 29. The petitioners’ communication of October 19, 2011.