94 engaging in the activities of human rights organizations. This obligation is reinforced in a known-context of insecurity for the activity of human rights defenders. 326. The proven facts and the analysis laid out in previous sections evidence the violence endured by Ms. Rúa, Figueroa, Naranjo, Mosquera and Yarce, which has restricted their activities as human rights defenders in Comuna 13. 327. In this sense, the forced displacement of Ms. Rúa and Figueroa compelled them to abandon their leadership positions in the AMI, and the Community Action Board out of fear of accusations, persecution, and other acts in retaliation for their endeavors.462 They are also impeded from returning to perform their duties inasmuch as they cannot be guaranteed a safe return to Comuna 13 under current security conditions there. 328. As indicated above, Mmes. Naranjo, Mosquera, and Yarce were subject to illegal and arbitrary detention on November 12, 2002 in the terms described in paragraphs 237-249. This detention and the subsequent investigative process not only interfered with their work as human rights defenders, but also stigmatized the work of the AMI, and of the Community Action Board in Comuna 13. Ms. Naranjo testified, in the context of the investigation into the assassination of Ms. Yarce, in the following terms: It was all triggered by her detention, that was on October 29 after Operation Orion, two years ago, then Teresa, Socorro Mosquera and I left jail, and since there were paramilitary groups, and we were accused of being collaborators with the militias, then the threats started. Teresa and I left for Independence Three Neighborhood, and we continued to belong to the Community Action Board, in other words, being community leaders, and the threats were that we had to leave the neighborhood or otherwise we would be killed, the guys would verbally tell us the people who called themselves the Self-Defense Forces were starting to come to the neighborhood, they would tell us to our faces, we would not answer them, we started to just go 463 about our normal business and to prevent them from robbing the young men to kill them …. 329. The Commission also has consistently deplored the continuing “threats, harassment and murders” linked to the ongoing community leadership work of Mrs. Mosquera and Naranjo in Comuna 13.464 As noted above (paragraphs 28-33), both have been the beneficiaries of precautionary measures since 2004 and provisional measures granted by the Inter-American court since 2006; and it has been verified by both the IACHR and the Court that implementation by the State of these measures has been ineffective, despite the State being aware of the situation of risk faced by the ladies.465 The IACHR, as well as the Court, have expressed their concern over the murder of the three family members of these defenders during the period that the precautionary and provisional measures were in effect – including the 16-year old grandson, and son-in-law of Mery Naranjo; the 14-year-old grandson of Socorro 462 Annexes 3 and 15. Statements of Miryam Eugenia Rúa and Luz Dary Ospina Bastidas Figueroa received by the GIDH addressed to the Inter-American Commission on Human Rights, April 27, 2012. 463 Annex 72. Statement of Mery Naranjo, Office of the Attorney General of the Nation, December 13, 2004, Criminal proceeding on the murder of Mrs. Ana Teresa Yarce. 464 Also see, for example, IACHR, Press Release, IACHR Condemns Continued Threats and Murders Directed against Human Rights Defenders and their Families in Colombia, March 7, 2011. 465 Also see, for example, IACHR, Press Release, IACHR Condemns Continued Threats and Murders Directed against Human Rights Defenders and their Families in Colombia, March 7, 2011.

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