6 to the one that arises with regard to the effectiveness of a judgment declaring the violation of rights, in itself, to repair the wrong perpetrated, as regards the moral satisfaction of the victim; an issue that has been dealt with by international jurisprudence and several of the Court's decisions. The Court has reiterated in its jurisprudence that, with regard to the request that the State should make a public apology as reparation of the violations committed, “the judgment on merits in the […] case constitutes, in itself, a significant and important form of reparation and moral satisfaction for [the victim] and his relatives. 5” 22. This is the first time that the Court has explicitly referred to the right to the truth, cited in the Commission's application. The innovation that the judgment contributes on this point could lead to further examination in the future, which would help to strengthen the role of inter-American human rights jurisprudence as a factor in the fight against impunity. Society's demand for knowledge of the facts that violate human rights and the individual right to know the truth are clearly addressed at banishing impunity, which encourages human rights violations. IV. APPLICATION OF THE GENEVA CONVENTIONS 23. The Court's decision also makes some observations about the applicability to this case of Article 3, common to the Geneva Conventions. In this respect, it is clear that the competence of the Inter-American Court to decide litigations, ratione materiae, is circumscribed to violations of the American Convention on Human Rights, since it is expressly invested with contentious jurisdiction to hear cases relating to “the interpretation or application” of this Convention (Article 62(1) and 3); to this could be added those expressly assigned to the Court by other treaties or conventions in force in America, such as the Inter-American Convention to Prevent and Punish Torture, a hypothesis that is also examined in this judgment. Thus, the Court cannot directly apply the rules of international humanitarian law embodied in the 1949 Geneva Conventions and, pursuant to them, decide a dispute, determining that there has been a violation of the provisions of those conventional instruments. 24. As the Court itself has indicated6, the foregoing does not preclude taking into consideration these provisions of international humanitarian law - another perspective of the international system - in order to interpret the American Convention. It is not an issue of directly applying Article 3 common to the Geneva Conventions in the case, but of admitting the facts provided by the whole system of laws - to which this principle belongs - in order to interpret the meaning of a norm that the Court must apply directly. 25. The Court can go further in its appreciation of this matter, even when it is not strictly required to under the terms of the application, and observe the presence of norms of jus cogens resulting from the evident correlation - which shows an international consensus - between the provisions of the American Convention, the 5 Thus, in the Suárez Rosero case. Reparations (Article 63.1 American Convention on Human Rights). Judgment of January 20, 1999. Series C No. 44, para. 72; Loayza Tamayo case. Reparations (Article 63.1 American Convention on Human Rights). Judgment of November 27, 1998. Series C No. 42, para. 158; and Caballero Delgado and Santana case. Reparations (Article 63.1 American Convention on Human Rights). Judgment of January 29, 1997. Series C No. 31, para. 58. 6 cf. Las Palmeras case, Preliminary objections. Judgment of February 4, 2000, paras. 32-34; here, it is noted that the American Convention “has only attributed the Court with competence to determine whether the acts or the laws of the States are compatible with the Convention itself, and not with the 1949 Geneva Conventions.”

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