40 adequate reparation and that this provision reflects a customary norm that constitutes one of the fundamental principles of contemporary international law of State responsibility.204 144. Reparation for the damage caused by the infringement of an international obligation requires, to the extent possible, full restitution (restitutio in integrum), which consists in the restoration of the prior situation. If this is not possible, as occurs in most cases of human rights violations, the Court will determine the measures to guarantee the infringed rights and to repair the consequences of the violation.205 Reparations must have a causal link with the facts of the case, the violations declared, the proven harm, as well as the measures requested to repair the resulting harm.206 145. In view of the declared violations of the Convention and in light of the criteria established in the Court’s case law with respect to the nature and scope of the obligation to repair,207 the Court will analyze the claims and arguments of the Commission and of the parties. Although the judgment, per se, is a form of reparation,208 the Court shall establish other measures in view of the harm caused to the victims. 146. Before entering into the pertinent details, the Court notes that the State reported that it has a National Program of Indemnification (hereinafter also “PNR”), created by Decree 258-2003. The State indicated that main objective of the PNR is to individually and/or collectively indemnify the victims of human rights violations resulting from the internal armed conflict. Guatemala, in its final written arguments, requested that the Court consider the benefits of the economic and housing compensation granted by the State to the Community, for which it attached a PNR document that provides a list of those persons who received some kind of benefit. The representative denied that the victims had received reparations from the PNR due to the massacre. The Court welcomes the actions undertaken by the PNR to repair the human rights violations caused by the internal armed conflict.209 Nevertheless, it notes that the State’s request is untimely and cannot be considered210 and reminds that the Court’s role is to ensure that the consequences of the human rights violations declared in this judgment are repaired. 211 It will, therefore, proceed to determine the appropriate reparations. of his right or freedom that was violated. The Court shall also rule, if appropriate, that the consequences of the measure or situation that constituted the breach of such right or freedom be remedied and that fair compensation be paid to the injured party. 204 Cf. Case of Velázquez Rodríguez v. Honduras. Reparations and Costs. Judgment of July 21, 1989. Series C No. 7, para. 25 and Case of Amrhein et al. v. Costa Rica, supra, para. 466. 205 Cf. Case of Velásquez Rodríguez v. Honduras. Reparations and Costs, supra, paras. 25 and 26 and Case of Amrhein et al. v. Costa Rica, supra, para. 467. The Court, depending on the case, has deemed that measures of restitution, rehabilitation, satisfaction and guarantees of non-recurrence have a special relevance for the harm caused (cf. Case of Cantoral Benavidez v. Peru. Reparations and Costs. Judgment of December 3, 2001. Series C No. 88, paras. 79 to 81 and Case of Amrhein et al. v. Costa Rica, supra, para. 467). 206 Cf. Case of Ticona Estrada et al. v. Bolivia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 191, para. 110 and Case of Amrhein et al. v. Costa Rica, supra, para. 468. 207 Cf. Case of Velásquez Rodríguez v. Honduras. Reparations and Costs, supra, paras. 25 to 27 and Case of Amrhein et al. v. Costa Rica, supra, para. 469. 208 Cf. Case of Neira Alegría et al. v. Peru. Reparations and Costs. Judgment of September 19, 1996. Series C No. 29, para. 56 and Case of Amrhein et al. v. Costa Rica, supra, para. 474. 209 Case of the Members of the Village of Chichupac and neighboring communities of the Municipality of Rabinal v. Guatemala, supra, para. 279. 210 The State’s request that the benefits already given through the PNR be considered is untimely for having been included in the final written arguments. Moreover, it should be mentioned that the document presented as proof of the benefits received by the members of the Community does not provide sufficient information to consider them as reparations for the case. 211 Case of the Members of the Village of Chichupac and neighboring communities of the Municipality of Rabinal v. Guatemala, supra, para. 281.

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