23 77. In turn, in the CEH Report, the case of Florencio Chitay Nech was documented as a credited case of forced disappearance. In this sense, the CEH Report points out that “the [M]unicipal [C]ouncil of San Martín Jilotepeque was completely dismantled. The forced disappearance of Felipe Álvarez was followed by the forced disappearance of the [F]irst [C]ouncilman, Mr. Florencio Chitay Nech.”74 78. As a consequence of the abovementioned, the surviving members of the Municipal Council of San Martín Jilotepeque jointly resigned and requested that new elections be called on January 8, 1981.75 79. More than 29 years after the facts took place, Florencio Chitay Nech is still missing, and there is no knowledge regarding his whereabouts of the location of his remains. 2. Forced Disappearance as a multiple violation of human rights 80. As stated before, (supra para. 19) there is no controversy regarding the facts and the rights that formed the forced disappearance of Florencio Chitay Nech, apart form that regarding the violation of the acknowledgement of his right to juridical personality, established in Article 3 of the American Convention, since the State denied its international liability (supra para. 20). 81. Despite the aforementioned statements, the Court reiterates its constant jurisprudence in the sense that, when analyzing an alleged forced disappearance, the continuous nature and its multi-offensive character shall be taken into account.76 82. The Court notes that attention from the international community to this phenomenon is not recent. The Working Group on Forced and Involuntary Disappearances of Persons of the United Nations developed, from its conception in the decade of the 80s, an operative definition of the phenomenon, highlighting in the definition the unlawful detention by agents or governmental agencies or organized groups of private individuals acting in the name of the State or counting on its support, authorization, or consent. 77 83. Likewise, the definition of the Declaration on the Protection of Persons against Forced Disappearance of 199278, establishes that forced disappearances occur in cases where: a person is arrested, detained, or transported against their will, or that they are deprived of their liberty by another means by governmental agents of any sector or level, by organized groups, or 74 Cf. CEH, Guatemala: Memory of Silence, supra note 35, Tome VIII, Annex II, Case No. 707, page 175. It should be noted that the Report mentions that the forced disappearance of Florencio Chitay Nech occured on 10 of December of 1980, nevertheless, as it was established, his disappearance occured on 1 of April of 1981. 75 Cf. CEH, Guatemala: Memory of Silence, supra note 35, Tome VIII, Annex II, Case No. 707. 76 Cf. Case Molina Theissen V. Guatemala. Merits, supra note 50, para. 41; Case of the Serrano Cruz Sisters V. El Salvador. Preliminary Exceptions. Judgment of 23 of November of 2004. Series C No. 118, para. 100, and Case Heliodoro Portugal V. Panamá. Preliminary Exceptions, Merits, Reparations and Costs. Judgment of 12 of August of 2008. Series C No. 186, para. 112. 77 Cf. Human Rights Commission. Report of the Working Group on Forced and Involuntary Disappearance of Persons, report carried out on the Sri Lanka visit by three members of the Working Group, 7 to 18 of October of 1991, E/CN.4/1992/18/Add. 1 of 5 of January of 1992. 78 Approved by the General Assembly in its Order 47/133 of 18 of December 1992, A/RES/47/133.