50 systematic patterns that allowed serious human rights violations to be committed.256 In other words, the facts cannot be considered in isolation. Therefore, in order to guarantee its effectiveness, the investigation must be conducted taking into account the complexity of the facts, which occurred in the context of counterinsurgency operations carried out by the Armed Forces, and the structure to which the individuals who were probably involved in them belonged. Thus, the State must make full use of its investigative powers so as to avoid any omission in the collection of evidence and in following logical lines of investigation, in order to effectively determine the whereabouts of the disappeared victims, clarify what happened, identify those responsible and, if appropriate, punish them. 155. The representatives, the Commission and the State agreed that the General Amnesty Law for the Consolidation of Peace has not been applied in the cases sub judice. However, the Commission and the representatives affirmed that the fact that this Amnesty Law is still in force constitutes a disincentive for the authorities in charge of the investigations to act (supra paras. 128 and 133). 156. From the evidence provided, it is clear that Legislative Decree Nº 486 “General Amnesty Law for the Consolidation of Peace,” issued in El Salvador on March 20, 1993, 257 has not been expressly applied in order to close the investigation initiated as a result of the facts of this case. However, the Court has verified that, at least in the investigation into the disappearance of José Adrián Rochac Hernández, the case file contains a copy of the Law of National Reconciliation and of the General Amnesty Law for the Consolidation of Peace, together with a report that mentions a communication sent by the prosecutor in charge of the investigation to the human rights prosecutor, who had indicated that this law was not applicable to the crime of forced disappearance of persons. This demonstrates that, given the lack of a clear institutional position on the criminal prosecution of actions such as those in the instant case, doubts persist as to whether the Amnesty Law would or would not be applicable in such cases. These doubts, in turn, are reflected in the limited progress made in the investigations. 157. From the information provided by the representatives and the State, it appears that to date the State has not adopted measures, in relation to grave human rights violations, designed to ensure that the aforesaid Amnesty Law did not produce effects in the past, does not have any at present, and will not produce effects in the future. As to the ruling issued by the Constitutional Chamber of the Supreme Court on September 26, 2000, in files 24-97 and 21-98, the Court pointed out in a previous case that in practical terms, this had not resulted in the re-opening of the investigations.258 Moreover, there is no evidence that the body in charge of criminal prosecutions has issued a directive on the non-applicability of that law to the investigation of facts such as those in this case, which in turn could cause the procedures undertaken to amount to a mere formality but not to a firm decision to advance in the investigations. 158. The Court considers it pertinent to recall that in the cases of the Serrano Cruz Sisters v. El Salvador and Contreras et al. v. El Salvador, concerning human rights violations involving the forced disappearance of children during the armed conflict, the Court held that because these were grave human rights violations, and given the continuing or ongoing nature of forced disappearance, in which Cf. Case of La Rochela Massacre v. Colombia. Merits, reparations and costs. Judgment of May 11, 2007. Series C No. 163, para. 156, and Case of the Massacres of El Mozote and nearby places v. El Salvador, supra, para. 257. 256 Legislative Decree in force from March 22, 1993, which states: “Full, absolute and unconditional amnesty shall be granted to all those who participated, in any way, in committing political crimes or common crimes related to political crimes, or in common crimes committed by at least 20 individuals prior to January 1, 1992, even if judgment has been handed down against such persons, or proceedings have been initiated against them, and this pardon shall apply to all those who have participated.” Cf. Legislative Decree N° 486, Ley de Amnistía General para la Consolidación de la Paz (General Amnesty Law for the Consolidation of Peace), of March 20, 1993, published in the Official Gazette N° 56, Volume 318, of March 22, 1993 (evidence file, volume VIII, folios 4016 to 4019). 257 258 Cf. Case of the Massacres of El Mozote and nearby places v. El Salvador, supra, paras. 293 and 294.