58 democracy and the lack of independence of the Venezuelan public authorities,” since such violation results from the interference of the Executive Branch, directly through the President of the Republic, upon the constitutional powers of the Judiciary.” The Commission did not allege any violation of these articles but announced “their enforcement […] as interpretation guidelines.” The State did not present arguments on this matter. 217. In its prior decisions, the Court has resorted to Article 29 of the Convention in three diverse instances. Firstly, the Court has referred to the “Restrictions Regarding Interpretation” of Article 29 to define the content of certain provisions of the Convention.231 In this regard, subparagraph (a) has been used to define the scope of the restrictions to the guarantees established in the Convention.232 Similarly, pursuant to subparagraph (b) of the Article, the Court has construed the guarantees contained in the Convention in accordance with the standards established in other international instruments233 and domestic laws.234 Furthermore, subparagraph (c) 231 The Court found it was convenient to “bear in mind the significance of the prohibition of forced or compulsory labor, in light of the general rules of interpretation established in Article 29 of the Convention;” to that effect “the Court f[ound] it useful and appropriate to use other international treaties than the American Convention.” Cf. Case of the Ituango Massacres v. Colombia. Preliminary Objection, Merits, Reparations and Costs. Judgment of July 1, 2006. Series C No. 148, paras. 154 and 157. Furthermore, the Court found that “[n]ote should also be taken of the provisions of Article 29 of the Convention” in order to “determine whether the proceedings to which Articles 25(1) and 7(6) apply are included among the essential judicial guarantees referred to in Article 27(2).” Cf. Habeas corpus in Emergency Situations (Arts. 27(2), 25(1) and 7(6) American Convention on Human Rights). Advisory Opinion OC-8/87 of January 30, 1987. Series A No. 8, paras. 15 to 17. 232 In this regard, it has been established that the ultimate responsibilities that could limit the right to freedom of expression should not only be “necessary”, as set forth in Article 13, but more specifically “necessary for a democratic society.” Cf. Compulsory Membership in an Association Prescribed by Law for the Practice of Journalism (Arts. 13 and 29 American Convention on Human Rights). Advisory Opinion OC5/85 of November 13, 1985. Series A No. 5, paras. 41 to 44. Article 29 has also been resorted to indicate that “a reservation may not be interpreted so as to limit the enjoyment and exercise of the rights and liberties recognized in the Convention to a greater extent than is provided for in the reservation itself.” Cf. Restrictions to the Death Penalty (Arts. 4(2) and 4(4) American Convention on Human Rights). Advisory Opinion OC-3/83 of September 8, 1983. Series A No. 3, para. 66 and Case of Boyce et al. v. Barbados. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 20, 2007. Series C No. 169, para. 15. Furthermore, the scope of the reservations or conditions that States may impose upon accepting the contentious jurisdiction of the Court has been construed. In that regard, the Court established that “it would be meaningless to suppose that a State which had freely decided to accept the compulsory jurisdiction of the Court had decided at the same time to restrict the exercise of its functions as foreseen in the Convention.” Cf. Case of Benjamin et al. v. Trinidad and Tobago. Preliminary Objections. Judgment of September 1, 2001. Series C No. 81, para. 81 and Case of Constantine et al. v. Trinidad and Tobago. Preliminary Objections. Judgment of September 1, 2001. Series C No. 82, para. 81. 233 In this sense, the inclusion of communal property in the case of the indigenous or tribal communities within the right to private property under Article 21 should be highlighted. Cf. Case of the Mayagna (Sumo) Awas Tingni Community v. Nicaragua. Merits, Reparations and Costs. Judgment of August 31, 2001. Series C No. 79, paras. 147, 148 and 153; Case of the Yakye Axa Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of June 17, 2005. Series C No. 125, paras. 124, 126 and 127; Case of the Sawhoyamaxa Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of March 29, 2006. Series C No. 146, paras. 117 and 118, and Case of Saramaka People v. Surinam. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 28, 2007. Series C No. 172, paras. 92 and 93. Furthermore, the construction whereby Article 22 of the Convention covers “the right to not be forcefully displaced.” Cf. Case of the “Mapiripán Massacre” v. Colombia. Merits, Reparations and Costs. Judgment of September 15, 2005. Series C No. 134, para. 188. Another example is the right of children not to be recruited in the armed forces or other groups set forth in Article 19 of the Convention. Cf. Case of the “Mapiripán Massacre,” para. 153. 234 In accordance with domestic legislation, the Court has allowed the construction of “a right to property related to the patrimonial effects of the right to a pension” under Article 21 (Cf. Case of the “Five Pensioners” v. Peru. Merits, Reparations and Cost. Judgment of February 28, 2003. Series C No. 98, paras. 101 to 103) and the need for specific protection of the political rights for the members of ethnic and indigenous communities (Cf. Case of Yatama, supra 63, paras. 203 to 205).