violations of the right to life of human rights defenders in Venezuela between 1997 and 2007.” This report also mentions the attack against Joe Luis Castillo, among others.64 120. The representatives referred to the 2007 Report of the Vicariate of Caracas on the Situation of Human Rights Defenders in Venezuela, which contains an assessment of the situation of human rights defenders in Venezuela during the period covered in 1997-2007.65 The report notes a significant deterioration in their working conditions during this “decade, particularly from 2004, when the political polarization in Venezuelan society reached its peak, and the attitude of the Venezuelan State changed with regard to NGOs and human rights defenders.” This report also contains a record, inter alia, of threats, smear campaigns, assaults, monitoring and surveillance, arbitrary arrests, attacks, killings and executions of “defenders of land rights,” “labor rights activists” and “defenders from NGOs or committees of relatives of victims of violations of the right to life”, among others, during the period mentioned previously. 121. Finally, in the Commission's Annual Report for 2003, the period in which the events of this case occurred, in the section on the situation of human rights defenders, the Commission noted that this situation [against defenders] d[id] not constitute a general practice; nevertheless, the existence of specific cases is a sign of serious impairment to human rights in the sense that in Venezuela the work of human rights defenders [had been] developing in a context free from setbacks of this nature.66 122. In relation to the preceding paragraphs, it should be noted that the Court has held that the right to life plays a key role in the American Convention, as it is the essential corollary for realizing the other rights67; that States have the obligation to ensure the creation of such conditions as may be required to avoid violations of this inalienable right and, specifically, the duty to prevent attempts against it by agents of the State68; that compliance with Article 4 of the American Convention, in relation to Article 1(1) thereof, not only assumes that no one shall be deprived of his life arbitrarily (negative obligation), but also, in light of the State’s obligation to guarantee the full and free exercise of human rights, it requires States to adopt all appropriate measures to protect and preserve the right to life (positive obligation). This active protection of the right to life by the State involves not only its legislators, but all State institutions and those responsible for safeguarding 64 The Commission indicated that “[t]he other five killings of defenders referred to in the report of the Human Rights Vicariate of Caracas are related to the activities of relatives of victims of extrajudicial executions in Venezuela, and among them is José Ramón Rodríguez, presumably executed by regional police officers of Portuguesa on October 28, 2000 and Enmari Dahiana Cava Orozco, presumably killed by municipal police officers from Cagua on March 10, 2003”. Report on Democracy and Human Rights in Venezuela, on December 30, 2009, paras. 623 and 626 (File of attachments to the Merits Report, Annex 14, pages 239 to 250). 65 supra. 66 Cf. Human Rights Vicariate of Caracas, Report on the Situation of Human Rights Defenders in Venezuela, Cf. IAHCR, Report on the Situation of Human Rights in Venezuela, supra. 67 Cf. Case of the “Street Children” (Villagrán Morales et al.) v. Guatemala. Merits. Judgment of November 19, 1999. Series C No. 63, para. 144, and Case of the Barrios Family v. Venezuela. Merits, Reparations and Costs Judgment of November 24, 2011. Series C No. 237, para. 48. 68 Cf. Case of the “Street Children” (Villagrán Morales et al.) v. Guatemala, Merits, supra, para. 144, and Case of the Barrios Family v. Venezuela, supra, para. 48. 30