purchase of private insurance in the United States of America and (d) tax on the outflow of foreign currency from his family during the years 2011 to 2016. Compensation was also requested for other expenses incurred, such as (e) books lost due to his forced exile, travel expenses, medical expenses not covered, and (f) investment in new means to carry out his work. Due to the above, they requested compensation of USD$1,845,281.94 (one million, eight hundred and forty-five thousand, two hundred and eighty-one United States dollars). 189. Regarding Carlos Nicolás Pérez Lapentti, Carlos Eduardo Pérez Barriga and César Enrique Pérez Barriga, the representatives stated that the material damage they suffered must be repaired in their capacity as shareholders of El Universo, which requires technical studies that transcend the work and expertise of a human rights court. Therefore, they requested that an arbitration court be established, with the required experience, to set the amount of compensation for the damages incurred to the detriment of the shareholders and directors of El Universo newspaper. 190. The State indicated that the representatives did not provide evidence that proves Mr. Palacio Urrutia's salary, and that the victim left his job voluntarily, therefore, he is not entitled to compensation for pecuniary damage. The State declared that, in the event that reparation for pecuniary damage is determined, it should be limited to the time frame of the events. Similarly, the State expressed that there is no causal link between the facts of the case and the sale of Mr. Palacio Urrutia's property, or any other expenses that may have arisen from his departure from the country. Regarding the request related to the directors of El Universo, the State stated that the company El Universo was not affected, so a measure of reparation or the requirement that an arbitration tribunal determine the alleged damage is not appropriate. 191. The Court has developed in its case law the concept of pecuniary damage and has established that this supposes “the loss or detriment to the victims’ income, the expenses incurred as a result of the facts and the consequences of a pecuniary nature that have a causal link with the facts of the case”. 241 192. In relation to the loss of earnings or loss of income, the Court observes that there is not enough information to determine the income that Mr. Palacio Urrutia effectively stopped receiving due to his resignation from El Universo, nor about the real economic impact that this had on his assets by having to practice his profession from the United States. Notwithstanding the foregoing, the Court considers that, considering the circumstances in which he left his job (supra par. 157 to 159), which forced his departure from the country, the victim found himself in a situation that affected his condition and employment opportunities, and that made it impossible for him to return to the country during the period between 2011 and 2017. Consequently, the Court finds it pertinent to award, in equity, an amount of USD$250,000.00 (two hundred and fifty thousand United State dollars) for loss of earnings in favor of Mr. Palacio Urrutia. 193. The Court observes that Mr. Palacio Urrutia incurred additional expenses that arose from the need to leave Ecuador to relocate to the United States of America. Although the State cannot be held responsible for all the expenses that could have been generated by reason of said transfer, it is evident that it generated expenses that had to be assumed by Mr. Palacio Urrutia and that have a direct connection with the circumstances that motivated his departure from the country. Consequently, the Court 241 Cf. Case of Bámaca Velásquez v. Guatemala. Reparations and Costs. Judgment of February 22, 2002. Series C No. 91, par. 43, and Case of Cuya Lavy et al. v. Perú, supra, par. 211. 60

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