32 108. In this regard, the representative argued that: a) covering the salary scales “was not the purpose of the new salary structure implemented by SEDAPAL.” Rather, “it was a response to an inflationary shock taking place at that time.” Specifically, the representative argued that the restructuring could not cover the amounts no longer being received because “the salary scale system had already been eliminated and its restoration [was] not being sought.” Additionally, the representative highlighted that the State itself recognized that the restructuring “does not cover the [s]alary [s]cales, [thus] eliminating the groundless justification put forward by the State for limiting the calculation”; b) “at no time has the salary restructuring been more beneficial than the salary scale system” as the latter was “permanent and successive;” c) “[the representative] takes into account the remuneration adjustment carried out in 1993, but it does not assign it any juridical significance, as in keeping with the guarantees established in the Political Constitution, no remuneration adjustment can nullify rights that have been granted to employees.” The Labor Ministry itself recognizes this; d) the last salary restructuring was carried out in 1997 and not in 2002, as the State has said. For this reason the representative argued that “it is false [...] that the company [...] implemented the remunerative policy approved in 2002,” and e) that if the State fully acknowledged its international responsibility for lack of judicial protection, it transgresses the Estoppel principle by not acknowledging the totality of pecuniary damages. 109. With regard to the representative’s argument that “it [did] not assign any juridical significance” to the salary restructuring in 1993 because it “nullified” workers’ rights, the Tribunal observes that specific evidence was not submitted before the Court invalidating the effects of that restructuring and contradicting the statements made in the expert witness report presented by the State and De Los Santos with regard to the way in which that restructuring had even improved employees’ salary-based remuneration at that time. 110. On the representatives argument that the salary scale system was more beneficial than the salary restructuring that took place in 1993, the Tribunal observes that this argument contradicts the representative’s position that the elimination of that system was valid because at the time of the facts, “measures were needed for national reactivation.” (supra paras. 62 and 78) 111. With regard to the supposed non-existence of salary increases in 2002, according to the evidence submitted by the representative,107 this is an issue that is under debate domestically. Also, the evidence submitted on the alleged lack of raises does not include 107 The representative reported that given the situation, on March 14, 2008, the SIFUSE of SEDAPAL “filed a judicial action […] before the Mixed Court of El Agustino, requesting the leveling off of the salaries that correspond to [w]orkers, [e]mployees, [p]rofessionals, and [t]echnicians of the noted [c]ompany, as a result of the approvals carried out by FONAFE as well as by SEDAPAL regarding the [p]olitical [r]emunerations for the year […] 2002, [j]udicial [a]ction in process.” Cf. Petition for leveling off of remunerations pursuant to a scale salary system, filed by the Union of Employees, Professionals and Workers of SEDAPAL on March 14, 2008, before the Mixed Court of the Basic Module of Justice of Agustino of the Superior Court of Peru (case file on the Merits, tome III, folios 1274 a 1288). The alleged situation of freezing salaires, undue relocation of subcategories presented by the representative as annexes to the brief of pleadings and motions. Nevertheless, the Court notes that only some of said statements make reference to the alleged interposition of legal complaints filed at a domestic level given the facts. Cf. Sworn statements of Messers. Luis Humberto Tori Gentille, José Miguel Toche Lora, Daniel F. Quinto Patiño, Marco Aurelio Benavides Galvez and Manuel Nava Valdeiglesias (case file of annexes to the brief of pleadings and motions, tome VI, annex 5, folios 1650, 1730, 1758, 1781 and 1789).