16 "The indivisibility between Articles 25 and 8 of the American Convention that I maintain (supra) leads me to characterize access to justice, understood as the full realization of justice, as forming part of the sphere of jus cogens; in other words, that the inviolability of all the judicial rights established in Articles 25 and 8 considered together belongs to the sphere of jus cogens. There can be no doubt that the fundamental guarantees, common to international human rights law and international humanitarian law, 65 have a universal vocation because they are applicable in any circumstance, constitute a peremptory right (belonging to jus cogens), and entail obligations erga omnes of protection. 66 Following its historic Advisory Opinion OC-18/03 on the Juridical Status and Rights of Undocumented Migrants, the Court could and should have given this other qualitative step forward in its case law. I dare hope that it will do so as soon as possible, if it truly continues with its forward-thinking case law – instead of trying to halt it – and extends the advance courageously achieved in this Advisory Opinion with the continuing expansion of the material content of jus cogens” (paras. 64-65). 48. I am particularly satisfied that, in this judgment on the Ituango Massacres, the Inter-American Court has, unanimously, remained true to its most lucid consistent case law in this respect, reiterating with great clarity its understanding that Articles 25 and 8 of the American Convention are ineluctably indivisible, as can be seen unequivocally from paragraphs 309 and 344 of this judgment. Likewise, paragraph 339 of this judgment observes correctly that: “(...) When establishing the international responsibility of the State for the violation of the human rights embodied in Articles 8(1) and 25 of the American Convention, a substantial aspect of the dispute before the Court is not whether judgments were delivered at the national level or whether conciliation agreements were reached on the civil or administrative responsibility of a State body with regard to the violations committed to the detriment of the victims of human rights violations or their next of kin, but whether the domestic proceedings ensured real access to justice, in keeping with the standards established in the American Convention.” VII. The reaction of the juridical conscience: the evolution of the notion of victim 49. The case of the Ituango Massacres gives rise to another line of reflection. The next of kin of the deceased and the surviving victims of the massacre have finally found justice before this international judicial instance. Through this judgment, those who were murdered have had their suffering recognized and their memory honored. The Court has also assessed positively the initiative of the defendant State in this dispute acknowledging its international responsibility for certain facts (although, I am surprised it did not extend that acknowledgment before this international jurisdiction to the juridical consequences of those facts). In brief, the juridical conscience (source of all law) was awakened to do justice to the victims of the Ituango massacre, which was inserted in a pattern of massacres that have plagued the country in question. 50. We must not forget that the notion of victim – on which I have been reflecting for many years 67 - continues to evolve in international human rights law. This 65 . E.g. Article 75 of Protocol I (1977) to the 1949 Geneva Conventions on international humanitarian law. 66 . Cf., likewise, see, e.g., M. El Kouhene, Les garanties fondamentales de la personne en Droit humanitaire et droits de l'homme, Dordrecht, Nijhoff, 1986, pp. 97, 145, 148, 161 and 241. 67 . Cf., e.g., A.A. Cançado Trindade, "Co-Existence and Co-Ordination of Mechanisms of International Protection of Human Rights (At Global and Regional Levels)", 202 Recueil des Cours de l'Académie de Droit International de La Haye (1987), chap. XI: "The Evolution of the Notion of Victim or of the Condition