harassment they suffered for being CAJAR members. The Commission deems that there is a sufficiently wellestablished causal link between the absence of investigation and effective protection measures and these individuals’ departure from the country to attribute responsibility to the State for their forced departure from Colombia for extended periods of time. 332. The Commission considers that this situation created great insecurity for them and a well-founded fear that their lives and personal safety were in peril if they remained in Colombia, which led to their exile.597 Therefore, the IACHR concludes that the State is responsible for violation of the right to movement and residence, protected under Article 22(1) of the American Convention, in connection with Article 1(1) thereof, to the detriment of Soraya Gutiérrez, Rafael Barrios, Luis Pérez, and Miguel Puerto, as well as their respective families. 333. The IACHR has information that some of those family members were minor children at the time of the events.598 The Commission thus concludes that the State violated its special protection duties regarding children, provided for in Article 19 of the American Convention, in relation to Article 1(1) thereof, to the detriment of Camilo Pérez, Karina Pérez, and Paula Romero. E. Rights to due legal guarantees, judicial protection, and access to information (Articles 8(1),599 25(1),600 and 13 of the American Convention, in relation to Article 1(1) thereof) 334. The IACHR and the Inter-American Court have found that any person who has suffered a violation of his or her human rights has the right to obtain from competent authorities of the State clarification of these human rights violations and determination of responsibility, through the investigation and prosecution provided for in Articles 8 and 25 of the Convention.601 Protection of these rights is strengthened by the general obligation to respect and guarantee [rights] imposed by Article 1(1) of the American Convention. In this respect, the Inter-American Court has provided that: Article 25 in relation to Article 1(1) of the American Convention obliges the State to guarantee to every individual access to the administration of justice and, in particular, to simple and prompt recourse, so that, inter alia, those responsible for human rights violations may be prosecuted and reparations obtained for the damages suffered (…) Article 25 “is one of the fundamental pillars not only of the American Convention, but of the very rule of law in a democratic society…” Said Article is closely linked to Article 8(1), which provides that every person has the right to a hearing, with due guarantees (…) for the determination of his rights, whatever their nature.602 335. Consequently, the States are obliged to take all measures to ensure that no one is deprived of [the right to] judicial protection or exercise of the right to a simple and effective recourse.603 Pursuant to the InterAmerican Court’s case law, “each State act that composes the investigation proceeding, and the entire investigation in itself, should be oriented at a specific purpose: the determination of the truth and the For further information see: I/A Court H.R. Case of Manuel Cepeda Vargas v. Colombia. Preliminary Objections, Merits, Reparations, and Costs. Judgment of May 26, 2010. Series C No. 213. 598 (i) The minors Camilo Ernesto Pérez Niño and Katia Karina Pérez Niño, children of Luis Guillermo Pérez Casas; and the minor Paula Camila Romero Gutiérrez, daughter of Soraya Gutiérrez Argüello. 599 Article 8(1) of the American Convention: Every person has the right to a hearing, with due guarantees and within a reasonable time, by a competent, independent, and impartial tribunal, previously established by law, in the substantiation of any accusation of a criminal nature made against him or for the determination of his rights and obligations of a civil, labor, fiscal, or any other nature. 600 Article 25(1) of the American Convention: Everyone has the right to simple and prompt recourse, or any other effective recourse, to a competent court or tribunal for protection against acts that violate his fundamental rights recognized by the constitution or laws of the state concerned or by this Convention, even though such violation may have been committed by persons acting in the course of their official duties. 601 IACHR, Report No. 56/12, Case 12.775, Merits, Florentín Gudiel et al., Guatemala, March 21, 2012, paragraph 108. I/A Court H.R. Case of Barrios Altos v. Peru. Judgment of March 14, 2001. Series C No. 75, paragraph 48. 602 I/A Court H.R. Case of Loayza Tamayo. Reparations. Judgment of November 27, 1998. Series C No. 42, paragraph 169. 603 I/A Court H.R. Case of Barrios Altos v. Peru. Judgment of March 14, 2001. Series C No. 75, paragraph 43. 597 65