by those violations. 184 Accordingly, the Court has considered the need to provide different types of
reparation in order to fully redress the damage; therefore, in addition to pecuniary compensation,
other measures such as satisfaction, restitution, rehabilitation, and guarantees of non-repetition have
special relevance owing to the severity of the harm caused. 185
163. The Court has also established that reparations must have a causal nexus with the facts of the
case, the violations declared, the damage proven, and the measures requested to redress the
respective harm. Consequently, the Court must analyze the concurrence of these factors in order to
rule appropriately and according to the law. 186
164. Therefore, taking into account the considerations on the merits and the violations of the
American Convention declared in this judgment, the Court will now examine the claims presented by
the Commission and the representatives of the victim, as well as the corresponding observations of
the State, in light of the criteria established in its case law concerning the nature and scope of the
obligation to make reparation, for the purpose of ordering measures to redress the harm caused. 187
A. Injured party
165. Pursuant to Article 63(1) of the Convention, this Court considers as injured party anyone who
has been declared a victim of the violation of any right recognized therein. Therefore, the Court
considers as “injured party” Sandra Pavez Pavez, who, as the victim of the violations declared in
Chapter VI, will be considered the beneficiary of the reparations ordered by the Court.
B. Measures of satisfaction and rehabilitation
B.1. Measures of satisfaction
a) Publication of the judgment
166. The Commission recommended that the State implement appropriate measures of
satisfaction; however, it did not refer specifically to these measures.
167. The representatives asked the Court to order the State to publish the judgment in a national
newspaper with wide circulation and on the websites of the relevant State institutions, particularly the
Ministry of Education and the Ministry of Foreign Relations, requesting also that the State be required
to make said publication available for one year.
168. As it has done in other cases, 188 the Court orders the State to publish, within six months of
notification of this judgment, in a legible and appropriate font size: a) the official summary of this
judgment prepared by the Court, once, in the Official Gazette; b) the official summary of this judgment
prepared by the Court, once, in a national newspaper with wide circulation, and c) this judgment in its
entirety, available for one year, on an official website of the State, in a manner accessible to the public
from the home page of the website. The State shall immediately inform this Court once it has issued
184
Cf. Case of Velásquez Rodríguez v. Honduras. Reparations and costs, supra, para. 24, and Case of Digna Ochoa and
Family Members v. Mexico, supra, para. 151.
185
Cf. Case of the Dos Erres Massacre v. Guatemala. Preliminary objection, merits, reparations and costs. Judgment of
November 24, 2009. Series C No. 211, para. 226, and Case of Digna Ochoa and Family Members v. Mexico, supra, para. 151.
Cf. Case of Ticona Estrada et al. v. Bolivia. Merits, reparations and costs. Judgment of November 27, 2008. Series C
No. 191, para. 110, and Case of Digna Ochoa and Family Members v. Mexico, supra, para. 152.
186
187
Cf. Case of Velásquez Rodríguez v. Honduras. Reparations and costs, supra, paras. 25 and 26, and Case of Former
Employees of the Judiciary v. Guatemala, supra, para. 136.
188
Cf. Case of Cantoral Benavides v. Peru. Reparations and costs. Judgment of December 3, 2001. Series C No. 88, para.
79, and Case of Digna Ochoa and Family Members v. Mexico, supra, para. 167.
42