8 most, but not all, of the workers. Panama has not been subjected to international sanctions for only having complied partially with the recommendations. The Freedom of Association Committee requested the State to “reinstate the workers, according to its needs”. Panama has complied with the ILO recommendations, in accordance with its economic capacity. The fact that the State began to comply with the recommendations halted the possibility of declaring that it has not complied. When the ILO issued the report that included its recommendations to the State, the latter was obliged to keep the ILO informed on progress with regard to the recommendations, and Panama has been complying with this obligation since 1992. The ILO is the only international instance competent to receive labor complaints. The complaints have to be presented through an international trade union organization as they cannot be presented directly by the trade unions, and they are channeled through the ILO Standards Directorate. Subsequently, according to the dimension of the complaints, they are transferred to the Freedom of Association Committee, the Experts Committee or the Tripartite Complaints Committee. The SITIRHE and SITINTEL unions presented the complaint to the Freedom of Association Committee, through the International Confederation of Free Trade Unions (CIOSL-ORIT). The number of workers was not defined to the ILO, as the number of persons affected varied in the different reports presented, and they were not individualized in the recommendations of the Freedom of Association Committee. The complaint, alleging the violation of ILO Conventions 87 and 98, which refer to freedom of association, only referred to the workers of the trade unions that presented it, SITIRHE and SITINTEL, and did not mention the other workers from other trade unions who were affected by Law 25. The complaint before the Freedom of Association Committee was restricted to the events that occurred in December 1990. The ILO only hears matters of a strictly work-related nature, so that it did not deal with due legal process as this was outside its competence. However, the point raised with regard to the labor courts of Panama refusing to accept the complaints of the workers without any legal justification is incorrect, because there were proceedings before that instance, filed by workers who considered that they had been unfairly dismissed. There were no objections to the statement of the witness, Antonio Ducreux Sánchez, so the Court considers that the facts that he declared are proved. V COMPETENCE 27. Panama has been a State Party to the American Convention since June 22, 1978, and recognized the jurisdiction of the Court on May 9, 1990. Therefore, under the terms of Article 62.3 of the Convention, the Court is competent to hear the preliminary objections filed in the instant case.

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