59 State, and the aggravation of the situation of juridical insecurity in which these communities find themselves. As the IACHR has indicated, the legal order, should provide the indigenous communities 311 effective security and legal stability with respect to their lands. Legal insecurity with respect to these rights renders indigenous and tribal peoples “especially vulnerable and open to conflicts and violation of 312 rights.” The existence of property titles that are in conflict with titles has been specifically identified by 313 the IACHR as a factor that causes legal insecurity for the indigenous communities. 222. In summary, the unilateral denial of the legal rights contained in commitments assumed by the State since 1975 and its own Constitution, laws and international obligations, and the consequent repudiation of the right that the indigenous communities of the Emberá people of Bayano to the effective performance and implementation of the agreements that recognized their property rights, constituted a violation of Article 21 of the American Convention, in connection with Articles 1(1) and 2. 223. As regards the Kuna indigenous people of Madungandí, the IACHR observes that recognition of their collective property rights over their lands and the obligation of the State to formally recognize this right was expressed, at least, in: (i) Cabinet Decree 123 of 1969, which provided for the 2 granting of new lands, as an area of 1,124.24 km was being alienated, that belonged to the Indigenous Reserve of Bayano of the construction of the hydroelectric dam; (ii) the Agreement of Farallón of 1976 in which the “National Government undertakes to demarcate the reserve and relocate the settlers and Indians”; (iii) Article 2(e) of Decree 5-A of 1982, which ruled out the adjudication of lots within their territories and established that their “demarcation is entrusted to the National Bureau of Indigenous 314 Policy” ; (iv) the agreement of September 6, 1983, among the Kuna of Madungandí, Emberá of Piriatí, and a representative of the Ministry of Interior and Justice by which it was agreed to establish boundaries 315 between those indigenous groups ; (v) the “Agreement of Mutual Accord” of 1984 in whose first point the State reiterated, through the Corporación para el Desarrollo Integral del Bayano, its obligation to create a comarca for the Kuna people of Bayano. In addition, as has been proven, there were multiple agreements and resolutions that stipulated the commitment to evict the non-indigenous persons who were illegally occupying their territories, which recognized that collective property rights that would prevail 316 over third persons. 224. The titles and rights that were derived from the agreements signed with the State pursuant to the Constitution and international obligations were not formally recognized until 30 years later, by Law 24 of January 12, 1996. The IACHR notes that this long process of claiming indigenous territory was marked by the successive signing of commitments and their systematic repudiation and failure to 311 IACHR, Second Report on the Situation of Human Rights in Peru. Doc. OEA/Ser.L/V/II.106, Doc. 59 rev., June 2, 2000, para. 19. 312 IACHR, Fifth Report on the Situation of Human Rights in Guatemala. Doc. OEA/Ser.L/V/II.111, Doc. 21 rev., April 6, 2001, Chapter XI, para. 57. 313 IACHR, Fifth Report on the Situation of Human Rights in Guatemala. Doc. OEA/Ser.L/V/II.111, Doc. 21 rev., April 6, 2001, para. 57. IACHR, Indigenous and Tribal Peoples’ Rights over their Ancestral Lands and Natural Resources: Norms and Jurisprudence of the Inter-American Human Rights System. OEA/Ser.L/V/II.Doc.56/09, December 30, 2009, para. 8. 314 Article 2(e) of Decree No. 5-A of April 23, 1982. ““Adjudication under any guise is prohibited of the state lands included and described: … (e) In the area of the Kuna and Emberá indigenous comarcas whose demarcation is entrusted to the National Bureau of Indigenous Policy and the leaders of those communities. While that physical demarcation is determined, the Kuna and Emberá communities may veto requests for adjudication of plots that belong to the territories of those comarcas.” 315 Annex 24. Agreement of September 6, 1983. Annex 14 to petitioners’ initial petition of May 11, 2000; and Annex 7 to the State’s communication of June 29, 2001. 316 Annex 30. Agreement of March 23, 1990. Annex 18 to petitioners’ initial petition of May 11, 2000; and Annex 11 to the State’s communication of June 29, 2001; Annex 31. Working Agreement for the Renewed Land Use Management of Alto Bayano signed by the Provincial Government of Panamá and the Kuna People of Wacuco, Ipetí, and other Communities of July 16, 1991. Annex to the summary of the petitioners’ intervention during the admissibility hearing of November 12, 2001; Annex 32. Resolution 002 of January 24, 1992. Annex 19 to petitioners’ initial petition of May 11, 2000; and Annex 14 to the State’s communication of June 29, 2001; Annex 33. Resolution 63 of March 17, 1992. Annex 20 to petitioners’ initial petition of May 11, 2000; and Annex 13 to the State’s communication of June 29, 2001.