B. Facts alleged by the representatives – factual framework 32. It has been the Court’s consistent case law that the alleged victims, their next of kin, or their representatives in the litigations before this Court may invoke the violation of rights other than those included in the application, provided they do not allege facts that are not included in the application, because the latter establishes the factual framework for the proceedings. In addition, since a contentious case is, above all, a litigation between a State and a petitioner or presumed victim, the latter may refer to facts that explain, contextualize, clarify or reject those mentioned in the application, or respond to the State’s claims by means of their arguments and the evidence they provide, without impairing the procedural balance or the adversarial principle, because the State is given the procedural opportunities to respond to these arguments at all stages of the proceedings.24 33. This case is the first submitted under the Court’s new Rules of Procedure in which, in accordance with their Article 35, the Commission submitted the case without an application, but rather by presenting the report referred to in Article 50 of the Convention. According to Article 35(3) of the Rules of Procedure, the Commission must indicate which of the facts contained in that report are submitted to the consideration of Court. In its submission brief, the Commission indicated that “it submit[ted] to the Court’s jurisdiction all the facts […] described in Report on Merits No. 11/10.” Thus, the Report on Merits constitutes the factual framework of the proceedings before the Court, so that it is not admissible to argue facts other than those described in it, without prejudice to indicating those that explain, clarify or reject the facts mentioned in the report. 34. The representatives indicated that, on June 19, 2004, police officials detained Gustavo Ravelo in the Camatagua police station and that his father “had to give money to the agent responsible for his custody to obtain his release.” In addition, they indicated that Victor Daniel Cabrera Barrios had been deprived of his liberty on several occasions in 2009, during which he had suffered ill-treatment, and received blows to his face and different parts of his body. 35. As regards their conformity with the factual framework presented in the Merits Report, the Commission did not refer to the above-mentioned facts described by the representatives. Also, in presenting these facts, the representatives did not argue that they were designed to “explain, clarify or reject” the facts mentioned in the Merits Report. The representatives merely noted, in relation to the alleged detention of Victor Daniel Cabrera Barrios, in a footnote, that “the Court was informed [of the said facts] in a brief of May 15, [2010],” in the proceedings on the provisional measures in force.25 In this regard, according to the above-mentioned criteria, the Court will not consider the facts alleged by the representatives that are not part of the Commission’s Report on Merits, or that do not explain, clarify or reject the facts it has presented. Accordingly, the Court will not refer to the legal arguments submitted by the representatives based on the above facts. VII RIGHTS TO LIFE, PERSONAL INTEGRITY, PERSONAL LIBERTY, AND RIGHTS OF THE CHILD, IN RELATION TO THE OBLIGATION TO RESPECT AND GUARANTEE RIGHTS 24 Cf. Case of the “Five Pensioners” v. Peru. Merits, reparations and costs. Judgment of February 28, 2003. Series C No. 98, para. 155, and Case of López Mendoza, supra note 16, para. 27. 25 Brief with pleadings, motions and evidence (merits file, tome II, folio 317). 16