72 . women,” nor did they explain the reasons why women became a greater target of attack “based on their condition [of being women].” What has been established in this case is that the alleged victims faced risky situations and in several cases were physically and verbally attacked by individuals in the exercise of their journalistic activities and not because of any other personal condition (supra paras. 131, 143 through 149). Therefore, it has not been proven that the facts were based on the gender or sex of the alleged victims. 280. Likewise, the Court considers that the representatives did not specify the reasons and the manner in which the State incurred in a behavior “directed or planned” against the alleged female victims, nor did they explain the measure in which the proven facts where they were affected “were aggravated by their female condition.” The representatives also failed to specify which facts and how they represent attacks that “affected women in an different [or] disproportional manner.” Similarly, they have not based their arguments on the existence of acts that, under Articles 1 and 2 of the Convention of Belém do Pará, can be defined as “violence against women,” or which would be “the appropriate measures” that, under Article 7(b) thereof, the State did not adopt in this case “to amend or repeal existing laws and regulations or to modify legal or customary practices which sustain the persistence and tolerance of violence against women.” In short, the Court considers that it is not correct to analyze the facts of the present case under the mentioned stipulations of the Convention of Belém do Pará. C) Investigation of the facts 281. The Court will refer to an argument presented by the Commission and the representative in order to attribute responsibility to the State for the actions of third parties, related to the fact that it did not effectively investigate the facts nor did it determine, prosecute, and punish those responsible. 282. The general obligation to guarantee the human rights acknowledged in the Convention, included in Article 1(1) can be fulfilled in different ways, based on the specific right the State must guarantee and the specific needs of protection.292 Therefore, it must be determined if in this case, and in the context in which the alleged facts occurred, the general obligation to guarantee imposed upon the State the duty to effectively investigate those facts as a way of guaranteeing the right to freedom of expression and to humane treatment, and thus avoid that they continue to occur. 283. The investigation of the violation of a specific substantive right may be a way to shelter, protect, or guarantee that right.293 The obligation to investigate “acquires special intensity and importance based on the gravity of the crimes committed and the nature of the rights infringed,”294 being able to even reach in some cases the nature of jus cogens. 295 In cases of extrajudicial killings, forced disappearances, torture, and other grave violations to human rights, the Tribunal has considered that carrying out an investigation ex officio, without delay and in a serious, fair, and effective manner is a fundamental element that 292 Cf. Case of Vargas Areco v. Paraguay. Merits, Reparations, and Costs. Judgment of September 26, 2006. Series C No. 155, para. 73; Case of Valle Jaramillo et al. v. Colombia, supra note 29, para. 97; and Case of García Prieto et al. v. El Salvador, supra note 53, para. 98. 293 Cf. case of the Pueblo Bello Massacre v. Colombia, supra note 80, para. 142; Case of Heliodoro Portugal v. Panama, supra note 27, para. 115; and Case of Zambrano Vélez et al. v. Ecuador, supra note 36, para. 110. 294 Cf. case of La Cantuta v. Peru, supra note 84, para. 157. See also Case of Goiburú et al. v. Paraguay, supra note 53, para. 128. 295 For example, in the case of La Cantuta v. Peru, it was determined that “the prohibition of the forced disappearance of people and the correlative duty to investigate it and punish those responsible have reached a status of jus cogens”. Cf. case of La Cantuta v. Peru, supra note 53, para. 157.