-108- 293. Arguments by the State a) as regards the beneficiaries, there is no obligation with the great majority of persons involved in the different cases included in these proceeding. Regarding those isolated cases that, exceptionally, have been decided by impartial commissions, the Peruvian State is ready to compensate them by applying any of the measures legally established by the corresponding applicable rules, at the election of each person and in accordance with the requisites provided for in said rules. Neither the Commission nor the common intervener for the alleged victims has complied with the request of the President, made at the public hearing, for the submission of a detailed list of the victims; b) as regards pecuniary damage: i. the State rejects the accounts filed by the common intervener in Appendixes 17 and 18 to the brief of requests and arguments as they “do not include the essential elements necessary to assess their content, as they only include general amounts without any indication of the items and partial amounts that add up to them;” ii. “a significant group” of the workers dismissed from the Municipality receive a adjustable pension; iii. the State admits its responsibility and is ready to compensate those workers whose cases have been reviewed by independent commissions. It does not deem itself obliged to compensate those who have not been positively declared eligible by said commissions. The State does not recognize the legal validity of rulings originated in acts of corruption and collusion; iv. as regards pensions, a distinction is worth making: the Peruvian State accepts the decision of those workers that, after being duly qualified by the commissions ad hoc, opt for this kind of compensation. With regard to workers not qualified by the commissions, the Municipalidad Metropolitana de Lima (Metropolitan Municipality of Lima) has been duly and punctually paying the pensions of all those entitled to them, without no reduction or impairment: the persons entitled to pensions have collected the total amounts due. Such pensions are determined on the basis of the remuneration paid to an active worker of similar position and are automatically adjusted when such remuneration is increased. “Therefore, there is no damage or harm to be compensated;” and v. as regards those persons who do not meet the requirements to be pensioned, in case they have been qualified by the commissions ad hoc, they are entitled to receive the alternative compensations established under the pertinent regulations. The other persons have no right to compensation as their dismissal has been qualified by default as ”valid and correct by the abovementioned commissions.” c) the State did not file any statement regarding compensations for nonpecuniary damages; d) as to the measures of satisfaction and the non-repetition guarantees, the State expressed that: