125. Notwithstanding the foregoing, the Court recalls that it is not possible to ignore the particular seriousness of attributing to a State Party to the Convention responsibility for the practice of human rights violations. This “requires the Court to apply an assessment of the evidence that takes into account the gravity of the attribution of international responsibility to a State and that, despite this, is able to create a conviction of the truth of the facts alleged.”78 Therefore, the analysis of the relevant background must be carried out having regard to its scope and characteristics, so as to be able to establish, if applicable, a pattern of violence against human rights defenders, of an allegedly flagrant and systematic nature. 126. In relation to this specific case, the Court notes that there is consensus between the parties and the Commission regarding the existence, at the time of the events, of a situation of insecurity and increased violence that affected the State of Zulia and particularly “campesino” leaders, as indicated by the uncontested and proven facts (supra paras. 34 to 37). Even the State acknowledged the general situation of insecurity in the area, and the fact that this had affected the “campesino” sector. 79 Accordingly, it stated that “[i]f the murdered “campesino” leaders are considered human rights defenders then, indeed, there was an increase in acts of aggression against human rights defenders in that area.” 127. However, the Court also notes that, on one hand, the references presented by the representatives and the Commission generally refer to the situation of human rights defenders in Venezuela and not exclusively to their situation in Zulia and, on the other, that, according to the evidence provided and beyond the complex situation of insecurity that existed in the area, in which certain events occurred that involved attacks against human rights defenders, it was not proven that these constituted a widespread situation or a systematic practice. Therefore, it is unnecessary for the Court to consider the other alleged circumstances, as well as the relevance of conducting an analysis based on the aforementioned increased obligation of prevention, in light of the presumed situation of “structural risk” (supra para. 104). 128. Based on the foregoing, it is necessary to indicate the requirements for attributing responsibility, in this case, for the State’s failure to discharge its positive obligation to Institutions to promote and protect human rights and universally recognized fundamental freedoms, states that "[e]veryone has the right, individually or collectively, to promote and to strive for the protection and realization of human rights and fundamental freedoms at the national and international levels.” Declaration on the Right and Responsibility of Individuals, Groups and Institutions to promote and protect human rights and universally recognized fundamental freedoms, A/RES/53/144, March 8, 1999, Article 1. See also United Nations, Basic Principles on the Role of Lawyers, adopted by the Eighth United Nations Congress on the Prevention of Crime and Treatment of Offenders, UN Doc No. A/CONF.144/28/REV.1, September 7, 1990, Articles 16 to 22, and the Council of the European Union, Draft on conclusions of the Council on EU guidelines for human rights defenders, 100056/1/04 REV 1, June 9, 2004. 78 Cf. Case of Velázquez Rodríguez. Merits, supra, para. 129, and Case of Vélez Restrepo and relatives v. Colombia, supra, para. 156. 79 In this regard, the State indicated that at the time of the events in this case, "[s]ome Venezuelan landowners started hiring Colombian paramilitaries as hit men to murder peasant leaders who were enforcing the Law on Land and Agricultural Development.” Observations presented by the State to the Commission, in a communication dated January 21, 2008, supra. In its 2003 Report on Human Rights in Venezuela the Ombudsman of Venezuela did not refer to attacks against specific people, but pointed out that [i]n the case of the deaths in peasant areas, during 2003 a pattern emerged that had already come to light publicly the previous year, of attacks targeting farm leaders, political activists, and human rights defenders using hired killers. Although the murders of two human rights activists were particularly noteworthy during 2003, the most vulnerable sector remained the peasants, whose leaders have been victims of attacks due to their efforts to organize and promote the right to land. Cf. Bolivarian Republic of Venezuela, Ombudsman Report 2003: Human Rights in Venezuela, supra. 32

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