32 ages. The Commission notes that the ages of the victims at the time of the events ranges from 9 months to 9 years, which means that the manifestations of fear and the sense of lack of protection could have varied in each case, without that meaning that there was no impairment. 177. With respect to the right to life, the Inter-American Court has recently indicated that “owing to the nature of forced disappearance, the victim is in an aggravated situation of vulnerability, which gives rise to the risk that several rights may be violated, including the right to life. This situation is accentuated in the presence of a systematic pattern of human rights violations and when children are involved … given that the illegal removal of their biological parents also jeopardizes the life, survival and development of the children146, the latter understood in its broadest sense to include its physical, mental, spiritual, moral, psychological, and social aspects.”147 178. While it is true that the disappearances of children have certain characteristics that distinguish them from other forms of forced disappearance, and experience has shown that there is a greater likelihood of finding the victims alive, those differences are not sufficient to refute the violation of the right to life in the instant case. The Commission notes that the case-law of the inter-American system on this point seeks precisely to establish the full scope of international responsibility in cases of forced disappearance in which the intrinsic risk it implies for the lives of persons is undeniable. In addition, an effort is made for the States to adopt all the measures within their reach to establish the victims’ whereabouts and, if they are found alive, to rebut the presumption of a violation of the right to life. 179. The Commission is of the view that the actions of the members of the military who deprived the victims in the instant case of liberty, appropriated them, and decided what to do with the victims in the instant case, without taking into consideration their special needs of protection or adopt other measures that would have made it possible to determine their identity, and, therefore, to facilitate immediate reunification with their families, all in a context of extreme and permanent violence such as that experience during the armed conflict in El Salvador, meant that the five children were placed in a situation of imminent risk to their lives at the hands of state agents. Up to date, after more than 30 years of the dissapearance, it has not been established the fate or whereabouts of any of the five victims of the instant case. 180. As for the right to recognition of juridical personality, the Commission recalls that this is an essential and necessary requirement for claiming and exercising all the rights, for without it the person does not enjoy the protection and guarantees offered by the law, simply because one is invisible in the eyes of the law. 181. By its very nature, forced disappearance of persons seeks the juridical annulment of the individual precisely in order to remove them from the protection that the laws and justice afford them. Thus, the apparatus of repression ensures that persons may be deprived of their rights with impunity by placing them beyond the reach of any possible judicial protection. The aim of those who perpetrate forced disappearance is to operate outside the law and conceal any evidence of crime, thereby seeking to avert its investigation and punishment, and prevent the person or their next of kin from filing suit or, in the event suit is filed, from accomplishing a positive result. 182. The Commission also notes that since its earliest case law, the Court has consistently 148 found that forced disappearance of persons comprises multiple offenses . This multiple violation of a 146 I/A Court H.R., Case of Contreras et al. v. El Salvador. Merits, Reparations, and Costs. Judgment of August 31, 2011. Series C No. 232, para. 90. Citing See: Case of Gelman, supra note 16, para. 130. 147 I/A Court H.R., Case of Contreras et al. v. El Salvador. Merits, Reparations, and Costs. Judgment of August 31, 2011. Series C No. 232, para. 90. Citing See United Nations, Committee on the Rights of the Child, General Comment No. 5, General measures of implementation of the Convention on the Rights of the Child (arts. 4, 42 and 44, para. 6)), CRC/GC/2003/5, November 27, 2003, para. 12. 148 I/A Court H.R., Case of Heliodoro-Portugal. Judgment of August 12, 2008. Series C No. 186, par. 106 and 112; Case of Goiburú et al. Judgment of September 22, 2006. Series C No. 153, pars. 81-85; Case of Gómez Palomino. Judgment of Continúa…

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