45 These advances towards the development of human rights in the continent have been incorporated into the Additional Protocol to the American Convention on Human Rights in the Area of Economic, Social and Cultural Rights "Protocol of San Salvador.”197 149. The recognition of the work in defense of the environment and its link to human rights is becoming more prominent across the countries of the region, in which an increasing number of incidents have been reported involving threats and acts of violence against and murders of environmentalists owing to their work.198 150. In the judgment rendered by this Court in the cases of Huilca-Tecse v. Peru and Cantoral-Huamaní and García-Santa Cruz v. Peru, it was held that freedom of association can only be exercised in a situation in which fundamental human rights are fully guaranteed and respected, particularly those related to the life and safety of the individual.199 In this regard, the impairment of the right to life or to humane treatment attributable to the State may, in turn, give rise to a violation of Article 16(1) of the Convention when such violation arises from the victim’s legitimate exercise of the right to freedom of association.200 151. As it has been established (supra paras. 50 to 52), at the time of death, Blanca Jeannette Kawas-Fernández was the president of the PROLANSATE foundation, and in that capacity she promoted the establishment of public policies on environmental protection in the department of Atlántida, Honduras, as well as awareness regarding natural resource preservation through education, and reported environmental degradation in the area. From the uncontroverted evidence presented, particularly from the statement rendered by Mr. Rafael Sambulá, former director of the foundation, on March 1, 1995, it is concluded that, before she died, Blanca Jeannette Kawas-Fernández reported “the problems affecting the protected areas” to the relevant authorities and the media[, …] “that individuals were 197 Cf. Additional Protocol to the American Convention on Human Rights in the Area of Economic, Social and Cultural Rights, "Protocol of San Salvador,” which expressly recognizes the right of every human being to live in a healthy environment (Article 11). 198 Cf. Inter-American Commission on Human Rights, Report No. 11/04 (admissibility), Petition 735/01, Teodoro García-Cabrera and Rodolfo Montiel-Flores, Mexico, February 27, 2004; Report No. 63/04 (admissibility), Petition 60/2003, Carlos Antonio Luna, Honduras, October 13, 2004; Report No. 58/06 (admissibility), Petition 1083/05, Erwin Haroldo Ochoa-López and Julio Armando Vásquez-Ramírez, Guatemala, July 20, 2006; Report No. 80/07 (Merits), Case 11.658, Martín Pelicó-Coxic, Guatemala, October 15, 2007. See also, among others, the following cases involving alleged violations of human rights of defenders, namely: Report No. 16/98 (admissibility), Case 11.324, Narciso González, Dominican Republic, March 3, 1998; Report No. 24/98 (Merits), Case 11.287, João Canuto De Oliveira, Brazil, April 7, 1998; Report No. 45/01 (admissibility), Case 11.149, Augusto Alejandro ZúñigaPaz, Perú, March 5, 2001; Report No. 82/01 (admissibility), Case 12.000, Anibal Miranda, Paraguay, October 10, 2001; Report No. 14/02 (admissibility), Petition 12.352, Bruce Campbell Harris-Lloyd, Guatemala, February 28, 2002; Report No. 55/06 (admissibility), Petition 12.380, Members of José Alvéar Restrepo Lawyers’ Collective, Colombia, July 20, 2006; Report No. 53/07 (admissibility), Petition 1193.03, María Nicolosa García-Reynoso, Mexico, July 24, 2007, and Report on the situation of human rights defenders in the Americas, March 2006, para. 220. See also, Report submitted by Ms. Hina Jilani, Special Representative of the Secretary-General on the situation of human rights defenders. A/HRC/4/37 January 24, 2007, para. 40. (Defenders working on land rights, natural resources or environmental issues seem to be particularly vulnerable to attacks and violations of their rights under the Declaration on Human Rights Defenders in countries of Latin America and in parts of Asia); and Amnesty International. Persecution and Resistance. The Experience of Human Rights Defenders in Guatemala and Honduras. August 2007, AI Index: AMR 02/001/2007 (record of appendixes to the brief of requests and arguments, appendix J, folio 1637). 199 Cf. Case of Huilca-Tecse. Merits, Reparations and Costs, supra note 183, para. 75; and Case of CantoralHuamaní and García-Santa Cruz. Preliminary Objection, Merits, Reparations and Costs, supra note 183, para. 146. 200 Cf. García-Santa Cruz. Preliminary Objection, Merits, Reparations and Costs, supra note 183, para. 147.