63 declaration on Bolivia’s non-compliance with said obligations is unnecessary because the previous declaration has general effects that transcend the specific case. 195. Furthermore, given that the Commission did not present arguments regarding the non-compliance with the obligation established in Article IV of the Convention on Forced Disappearance, nor did it refer to any relating of that provision to this case, the Court shall not rule on that aspect. B.5. About the non-applicability of statutory limitations to serious human rights violations 196. The Inter-American Commission argued that “the legal framework applicable to the accused constituted an obstacle to the punishment of those responsible for what happened to the victims.” It mentioned that “domestic authorities found that prosecution for the crimes of murder and torture were barred by the statute of limitations because by nature they are of immediate commission;” therefore, the only crime that should be maintained in the charges was the one of deprivation of liberty, since this crime is ongoing until the time in which the affected person recovers his or her liberty. The Commission specifically indicated that, in the case of Rainer Ibsen Cárdenas, the crime of unlawful deprivation of liberty was also considered time barred, since his remains appeared in 1983, time at which, his deprivation of liberty allegedly ended. The Commission concluded that “the prospects for obtaining justice through domestic criminal proceedings are minimal.” 197. This Court has held that that the prohibition of forced disappearance of persons and the correlative duty to investigate and punish those responsible for it are regulations that “have reached a nature of jus cogens.”230 Likewise, the jurisprudence of this Court, the orders of other international bodies and organizations, as well as other international instruments and treaties, such as the Declaration on the Protection of All Persons from Forced Disappearance of 1992, the Inter-American Convention on Forced Disappearance of Persons of 1994, and the International Convention for the Protection of All Persons against Forced Disappearance of 2006, provide for certain standards applicable to the investigation and the prosecution of this type of crimes.231 198. Given the urgent need to prevent forced disappearance cases from remaining unpunished, this Court recalls that it is imperative to use all criminal resources available in furtherance of protecting the fundamental rights that might have been infringed in those cases.232 In light of the foregoing, the Court considers it convenient to highlight that in its first rulings,233 it has identified the forced disappearance of persons as an illegal act of a continuous and permanent nature, consisting of multiple human rights violations. 230 Cf. Case of Goiburú et al. v. Paraguay, supra note 7, para. 84; Case of Radilla Pacheco v. Mexico, supra note 8, para. 139, and Case of Chitay Nech et al. v. Guatemala, supra note 6, para. 86. 231 Cf. Case of Bámaca-Velásquez v. Guatemala. Monitoring Compliance with Judgment. Order of the InterAmerican Court of Human Rights of January 27, 2009. Considering Clause 27, and Case of Trujillo-Oroza v. Bolivia. Monitoring Compliance with Judgment. Order of the Inter-American Court of Human Rights of November 16, 2009, Considering Clause 36. 232 Cf. Case of Heliodoro Portugal v. Panamá. supra note 1, para. 182, and Case of Trujillo-Oroza v. Bolivia. Monitoring Compliance with Judgment, supra note 231, Considering Clause 36. 233 Cf. Case of Velásquez Rodríguez v. Honduras. Merits, supra note 14, paras. 149 and 150; Case of Godínez-Cruz v. Honduras. Merits. Judgment of January 20, 1989. Series C No. 5, paras. 157 and 158, and Case of Fairén-Garbi and Solís-Corrales v. Honduras. Merits. Judgment of March 15, 1989. Series C No. 6, para. 147.