Investigations for Cases of Forced Disappearances, Arbitrary or Extrajudicial Executions," 116 and the "Minnesota Protocol on the Investigation of Potentially Unlawful Death." 117 77. The obligation to search for disappeared persons is not limited to situations of forced disappearance. Even in the event of the death of the disappeared person, the State has the obligation to adopt the necessary measures to clarify and determine their whereabouts. This obligation is regardless of whether the disappearance of the person is the result of the wrongful act of forced disappearance or of other circumstances such as their death in a military operation, errors in the delivery of the remains, or other reasons. 118 In cases in which a person has been deprived of their life, and their relatives do not know the circumstance of their death and the exact place where their remains are located, the State has the obligation to clarify the circumstances of the death and the location of the body. 119 78. The obligation to search for disappeared persons is independent and is neither subordinate nor conditioned to the obligation to investigate the crime of forced disappearance and to prosecute and punish its perpetrators. It persists regardless of the results of the criminal investigation and the identification and prosecution of those responsible. The logic of criminal proceedings is based on proof of the materiality of the crime with a view to prosecuting those responsible. Its nature is different from that of locating the remains of the disappeared person. That is why the "Guiding Principles for the Search for Disappeared Persons" provide that the criminal investigation or the eventual condemnatory or acquittal judgment should not be an obstacle to continuing with the search activities nor can they be invoked to suspend them. 120 Conversely, the obligation to search for disappeared persons does not exonerate the State from its obligation to investigate the crime of forced disappearance or to prosecute and convict its perpetrators and participants. Given the seriousness of this crime, the prohibition of the forced disappearance of persons and the corresponding obligation to investigate and punish those responsible has attained the status of jus cogens. 121 79. Consistent with this background, the Court must analyze the plurality of conducts that may come together in the commission of the crime of forced disappearance with a comprehensive approach that contemplates the possible continuous violation of legal rights protected by the Convention, in particular, the rights to juridical personality, life, humane treatment and personal liberty, enshrined in Articles 3, 4, 5, and 7. 122 In view of the above, consideration of the forced disappearances alleged in this case must take into account a series 116 International Consensus on Principles and Minimum Standards for Psychosocial Work in Search Processes and Forensic Investigations in Cases of Forced Disappearances, Arbitrary or Extrajudicial Executions. Guatemala: I World Congress on Psychosocial Work on Forced Disappearance, Exhumation Processes, Justice and Truth, Antigua, Guatemala. Recommended by the General Assembly of the Organization of American States, through Resolutions GA/RES. 2717 (XLII-O/12) of June 4, 2012 and GA/RES. 2794 (XLIII-O/13) of June 5, 2013. 117 Minnesota Protocol on the Investigation of Potentially Unlawful Death (2016), Office of the United Nations High Commissioner for Human Rights, New York and Geneva, 2017. 118 Case of Rodríguez Vera et al. (The Disappeared from the Palace of Justice) v. Colombia. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 14, 2014. Series C No. 287, para. 478. 119 UN Human Rights Committee, Case of Sankara et al. v. Burkina Fasso, Communication No., Decision of March 26, 2006, para. 12.2. 120 United Nations Committee on Enforced Disappearances, Guiding principles for the search for disappeared persons, adopted on April 16, 2019, at session no. 16, principle 13.4. 121 Cf. Case of Goiburú et al. v. Paraguay, supra, para. 84 and 131; Case of Maidanik et al. v. Uruguay, supra, para. 116, and expert opinion of Federico Andreu Guzmán rendered by affidavit on March 6, 2020 (case file of evidence, p. 8983-9012). Cf., Inter alia, Case of Velásquez Rodríguez v. Honduras. Merits, supra, paras. 150, 155-158, 186 and 187; Case of Godínez Cruz v. Honduras, supra, paras. 158, 163-167, 196, 197; Case of Anzualdo Castro v. Peru. Preliminary Objection, Merits, Reparations, and Costs. Judgment of September 22, 2009. Series C No. 202, paras. 68-103; Case of Isaza Uribe et al. v. Colombia. Merits, Reparations, and Costs. Judgment of November 20, 2018. Series C No. 363, para. 81, and Case of the Los Josefinos Village Massacre v. Guatemala, supra, para. 70. 122 26