24
situation.87 When this is not feasible, as in the majority of cases of human rights violations, this
Court will determine measures to guarantee the violated rights and to remedy the consequences of
those violations.88 Therefore, the Court has found it necessary to grant various measures of
reparation in order to redress the harm comprehensively; thus, in addition to pecuniary
compensation, measures of restitution, rehabilitation, and satisfaction, as well as guarantees of
non-repetition, have special relevance for the harm caused. 89
92.
This Court has established that reparations must have a causal nexus with the facts of the
case, the violations declared, the harm proven, and the measures requested to redress the
respective harm. Accordingly, the Court must analyze all of these factors in order to rule
appropriately and in keeping with law.90
93.
In view of the violations declared in this judgment, the Court will proceed to examine the
petitions made by the Commission and the representatives, as well as the arguments of the State,
in light of the tenets established in its case law in connection with the nature and scope of the
obligation to make reparations and thus adopt the measures required to redress the harm to the
victims.91
94.
International case law, in particular that of the Court, has repeatedly established that a
judgment constitutes a form of reparation in itself. 92 However, in light of the circumstances of this
case and the violations committed against the victim, the Court considers it appropriate to order
other measures.
A. Injured Party
95.
Pursuant to Article 63(1) of the Convention, this Court holds that an injured party is anyone
who has been declared a victim of the violation of any right recognized in the Convention. The Court
thus finds Manuel Martínez Coronado to be the “injured party.”
B. Measures of satisfaction
96.
The representatives requested as measures of satisfaction that the State be ordered to
publish the full text of the judgment in the Official Gazette of Guatemala and in another national
newspaper.
97.
The State did not refer specifically to the publication of the judgment.
98.
The Court orders, as it has in other cases, 93 that the State publish within six months of the
notification of this judgment: a) the official summary of this judgment prepared by the Court, once,
in the Official Gazette in a legible and appropriate font size; b) the official summary of the judgment
prepared by the Court, once, in a newspaper with broad national circulation in a legible and
Cf. Case of Velásquez Rodríguez v. Honduras. Reparations and Costs, supra, para. 26, and Case of Muelle Flores v.
Peru, supra, para. 221.
88
Cf. Case of Velásquez Rodríguez v. Honduras. Reparations and Costs, supra, para. 26, and Case of Muelle Flores v.
Peru, supra, para. 221.
89
Cf. Case of Cantoral Benavides v. Peru. Reparations and Costs. Judgment of December 3, 2001. Series C No. 88,
para. 79 to 81, and Case of Muelle Flores v. Peru, supra, para. 221.
90
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 Muelle Flores v. Peru, supra, para. 222.
91
Cf. Case of Andrade Salmón v. Bolivia. Merits, Reparations, and Costs. Judgment of December 1, 2016. Series C
No. 330, para. 189, and Case of Colindres Schonenberg v. El Salvador. Merits, Reparations, and Costs. Judgment of February
4, 2019. Series C No. 373, para. 121.
92
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 Muelle Flores v. Peru, supra, para. 267.
93
Cf. Case of Cantoral Benavides v. Peru, supra, para. 79, and Case of Muelle Flores v. Peru, supra, para. 239.
87