31 “the 18th Civil Court has ruled that the elimination of the salary scale system does not bring with it the obligation to eliminate the remunerative raises granted while the scale system was in force. This is because the law only calls for updates to remuneration to cease starting in 27.NOV.92. Therefore, the sums owed for the application of the salary scale system during the periods in which it was in force form part of the remuneration of the functionaries and must to the present day be included in the base calculation of compensation for labor.“ 104 105. As has been observed, the expert witness report presented by the State expressly indicates that “the raises granted” form part of the remunerations and must be taken into consideration when calculating benefits “to the present day.” This expert witness report calculates material damages as through the date of salary restructuring in 1993, since the company considers that that restructuring had “raised employee remuneration” and, in that sense, would include the salaries they were receiving prior to 1993 through the application of the salary scales. 106. The Court observes that with regard to the purpose of the salary restructuring in 1993, the expert De Los Santos noted that “SEDAPAL [did not set up] a structure with the salary scales in mind. [Rather] the expert was thinking of the challenges facing the State [...] and the company and therefore doing a total restructuring. For this reason, the new structure was not set up “for remunerative reasons, but rather for the purpose of modernizing the institution.”105 The testimony also indicated that the 1993 salary restructuring increased the salary-based remuneration of the company’s employees.106 107. Taking all this into account, the Court observes that although the representative and the State agree that the omission of a raise in salary for the victims should be considered “through the present day,” the two parties interpret that assertion differently. While the representative argues that from 1993 through the present day there is a failure to pay a portion of the salary that the workers acquired through the application of the salary scales, as well as the increase in employee salaries that should have been made in July 1992, the State argues that the benefits from the 1993 salary restructuring already include those amounts and that the employees therefore are not owed any salary reimbursement from 1993 to the present day. Given this, and as the State’s expert witness report specifies that the 1993 salary restructuring meant that the salary levels in force through the present day take into account the salary scale levels already part of the victims’ personal wealth, the Tribunal finds that the next step is to examine whether with this argument the representative rejected the idea that the restructuring included the failure to pay the amount added to the victims’ personal wealth through the application of the salary scales. 104 Cf. Expert Opinion of Mr. Félix Daniel Aquije Soler, supra note 29, folio 2580. 105 Cf. Statement rendered by expert witness Víctor Hugo De Los Santos, supra note 30. 106 In agreement with Mr. De Los Santos, the restructuring of salaries of 1993 created “a comprehensive structural and organized reform of the company and created increases in such a manner […] that the salary received by the employees in December 1992 increased on average in August 1993 up to a 111% in nominal value” and “considering that the inflation had a real effect of 63.29%.” As such, “any ration that may have been in that intermi of 8 months would always have been less than that offered by SEDAPAL in the new remunerative structure.” In this regard, Mr. De Los Santos formulated an example in the following terms: in the case of a professional in category 4, whose scale was 3.42, of 725 soles of salary, “without having provided an increase to unskilled worers [for the collective negotiation of 70 soles], without having given the difference of the [remuneration base from December 1991 to January 1992], without having returned the owed discount [that was made to the workers as a result of the enactment of Decree Law 25876], there is an increase of 96.46.” Now, "when establishing the new compensation structure, [...] of the salary of 725, we would have [increased] the increase to the unskilled worker that was [of] 70 soles, multiplied by the ratio gives us 239 soles of increase, the difference of the base that was 301 soles multiplied by the ratio was 102 soles, the owed discount provided to the worker should have been returned [to which] it would have reached a compensation of 1247 [soles] and that [...] was less than 1425 given by the new compensation structure." Cf. See Statement expert witness rendered by Victor Hugo De Los Santos, supra note 30.