20
73.
Regarding the obligation to continue to implement and, if applicable, develop
permanent human rights education programs within the Colombian armed forces, and
guarantee their effective implementation (operative paragraph twelve of the Judgment),
Colombia requested the Court to “take into account the information provided by the
State in the procedure to monitor compliance with the Judgment in the case of the
“Mapiripán Massacre” in which it gave details of the different activities carried out to
implement programs on human rights education, and international humanitarian law,
within the armed forces of the country." In that respect, it requested the Tribunal to
declare that Colombia had complied with operative paragraph twelve of the Judgment
“bearing in mind that the obligation ordered in this case is similar to the one ordered in
the case of the ‘Mapirián Massacre’ and 'Ituango Massacre,' in which the Court has
already declared compliance therewith.”
74.
The representatives did not present observations on the compliance with this
reparation measure.
75.
The Commission indicated that “as in the case of Mapiripán, […] it value[d] that
the State [was] implementing, within its armed forces, the courses on human rights and
international humanitarian law [...]."
76.
The Court notes that the reparation measure ordered in the instant case22 related
to human rights training within the Colombian armed forces is similar to the training
measures that Colombia was ordered to implement in the cases of the Mapiripán
Massacre and the Ituango Massacre. In the three judgments, the Tribunal ordered the
implementation of permanent programs on human rights within the Colombian armed
forces. In fact, in the cases of the Mapiripán Massacre and the Ituango Massacre, the
Court has already declared compliance with this measure by means of Orders issued in
July 2009.23
77.
Based on the similarity of the training measures ordered by the Court and taking
into account the State's request to admit, in this case, the information presented on
compliance with the training measure in the case of the Mapiripán Massacre, which was
not objected to by the representatives, the Tribunal considers it useful, based on the
principle of procedural economy, to admit such information into the case file, taking into
account that the Commission as well as the representatives have had the opportunity to
present observations on the matter in the case of the Mapiripan Massacre.24
22
In operative paragraph twelve and paragraph 303 of the Judgment, the Court ordered:
[…] the State must adopt measures designed to educate and train members of security
forces on the principles and rules governing the protection of human rights and
international humanitarian laws, including limitations that constrain them. To that end, the
State [should] effectively implement, within a reasonable time, permanent training
programs on human rights for the Colombian armed forces. The program sh[ould] place
particular stress on this Judgment and the State [should] guarantee its effective
implementation.
23
See Case of the Ituango Massacres V. Colombia; supra note 8, Considering Clauses 45 to 50;
Case of the Mapiripan Massacre V. Colombia; supra note 8, Considering Clauses 62 to 64.
24
In a similar sense, see Case of the Ituango Massacres V. Colombia; supra note 8, Considering
Clauses forty-nine.