the decisions of the Human Rights Committee of the International Covenant on Civil and Political Rights,156 and decisions of the highest domestic courts. 157 129. The forced disappearance of persons must be analyzed from an integral perspective owing to the multiple conducts that, combined towards a single purpose, violate permanently, while they subsist, rights protected by the Convention. 158 Thus, the legal analysis of forced disappearance must be consequent with the complex violation of human rights that it entails. 159 130. The Court has verified the international consensus when examining this crime, which constitutes a grave violation of human rights, given the particular significance of the violations involved and the nature of the rights harmed, that involves an evident abandonment of the essential principles on which the inter-American system is founded; 160 moreover, its prohibition has achieved the status of jus cogens. 161 131. Before beginning to analyze whether what happened to Mr. González Medina constitutes a forced disappearance and its legal consequences, this Court considers it pertinent to recall its case law regarding the criteria applicable to the assessment of the evidence in a case such as this one, owing to certain arguments of the State to the effect that the disappearance must be proved “beyond any reasonable doubt” and that there are no “serious, grave and consistent indications that destroy the presumption of innocence of those presumed to be implicated” under the domestic judicial investigation. 156 In this regard, see, Messaouda Grioua and Mohamed Grioua v. Algeria, CCPR/C/90/D/1327/2004 (2007), Communication No. 1327/2004, 16 August 2007; Yasoda Sharma and Surya Prasad Sharma v. Nepal, CCPR/C/97/D/1469/2006 (2008), Communication No. 1469/2006, 6 November 2008; Zohra Madoui and Menouar Madoui v. Algeria, CCPR/C/94/D/1495/2006 (2008), Communication No. 1495/2006, 1 December 2008, and Nydia Erika Bautista de Arellana v. Colombia, CCPR/C/55/D/563/1993, Communication No. 563/1993, 13 November 1995. 157 Cf. Case of Marco Antonio Monasterios Pérez, Supreme Court of Justice of the Bolivarian Republic of Venezuela, Judgment of August 10, 2007 (declaring the permanent nature and multiple offenses constituted by the crime of forced disappearance); Supreme Court of Justice of the Nation of Mexico, Judgment: P./J. 87/2004, “Enforced disappearance of persons. The time frame for calculating its prescription does not start until the victim appears or their whereabouts are established” (declaring that forced disappearances are permanent crimes and that prescription should be calculated as of the date perpetration ceases) Case on the withdrawal of immunity from Pinochet, Plenary of the Supreme Court of Chile, Judgment of August 8, 2000; Case of Sandoval, Court of Appeal of Santiago de Chile, Judgment of January 5, 2004 (all declaring that the crime of enforced disappearance is continuing, a crime against humanity, not subject to the statute of limitations, and not subject to amnesty); Case of Videla et al., the Argentine National Federal Criminal and Correctional Chamber of Appeal of the Capital, Judgment of September 9, 1999 (declaring that enforced disappearances are continuing crimes and crimes against humanity, and are not subject to the statute of limitations); Case of José Carlos Trujillo, Constitutional Court of Bolivia, Judgment of November 12, 2001 (declaring that enforced disappearances are continuing crimes and that prescription should be calculated as of the date perpetration ceases), and Case of Castillo Páez, Constitutional Court of Peru, Judgment of March 18, 2004 (declaring, as ordered by the Inter-American Court in the same case, that enforced disappearance is a permanent crime until the whereabouts of the victim has been established, and includes multiple offenses). 158 Cf. Case of Radilla Pacheco v. Mexico, supra note 50, para. 138, and Case of Contreras et al. v. El Salvador, supra note 51, para. 80. 159 Cf. Case of Heliodoro Portugal v. Panama, supra note 59, para. 112, and Case of Gelman v. Uruguay, supra note 150, para. 78. 160 Cf. Case of Velásquez Rodríguez v. Honduras. Merits, supra note 18, para. 158, and Case of Contreras et al. v. El Salvador, supra note 51, para. 83. 161 Cf. Case of Goiburú et al. v. Paraguay. Merits, reparations and costs. Judgment of September 22, 2006. Series C No. 153, para. 84; Case of Gomes Lund et al. (Guerrilha do Araguaia) v. Brazil, supra note 53, para. 105, and Case of Contreras et al. v. El Salvador, supra note 51, para. 83. 43