135. The IACHR also reiterates that the obligation of investigating and punishing all actions that constitute violations of Convention-protected rights requires that punishment be meted out not only to the physical perpetrators of human rights violations, but also the individuals who mastermind such offenses. 225 That is based on the right to the truth of the victim’s next of kin, which implies obtaining from the State’s competent agencies the elucidation of the truth about what happened and to ensure that all the persons responsible are punished,226 involving all institutions of the State in that undertaking.227 136. In addition, when the death of a human rights defender is involved, the Commission has ruled that the State must take into account his or her activities in order to identify the interests that might have been affected thereby and thus to establish lines of investigation and hypotheses about the crime.228 In turn, the Court has acknowledged that the fear felt by defenders at “the death of a human rights defender [in reprisal for his or her activities] can directly reduce the possibility of human rights defenders exercising their right to perform their work by means of denunciations.”229 The IACHR has underscored the fact that impunity in cases of this kind constitutes the factor that most increases the risk to defenders, because it leaves them in a situation of defenselessness and vulnerability. 230 1.1. Due diligence in investigating and clarifying the facts 137. The Court has held that whenever the State conducts an investigation into the alleged commission of a crime, it must ensure that it is oriented toward a specific purpose: “the determination of the truth through the identification, prosecution, and, if applicable, punishment of those responsible for the events.”231 To ensure that goal, the investigation must be carried out by means of all available legal means 232 and must be pursued with due diligence, effectively, seriously, and impartially. 233 1.1.1. Initial formalities 225 I/A Court H. R., Case of the Gómez Paquiyauri Brothers v. Peru, Merits, Reparations, and Costs, Judgment of July 8, 2004, Series C No. 110, para. 146; Case of Myrna Mack Chang v. Guatemala, Merits, Reparations, and Costs, Judgment of November 25, 2003, Series C No. 101, para. 275; Case of Juan Humberto Sánchez v. Honduras, Preliminary Objection, Merits, Reparations, and Costs, Judgment of June 7, 2003, Series C No. 99, para. 186; and Case of the Constitutional Court v. Peru, Competence, Judgment of September 24, 1999, Series C No. 55, para. 123. In addition, see: IACHR, Report on the Situation of Human Rights Defenders in the Americas, OEA/Ser.L/V/II.124 doc. 5 rev. 1, March 7, 2006, para. 109. 226 I/A Court H. R., Case of Gómez Palomino v. Peru, Merits, Reparations, and Costs, Judgment of November 22, 2005, Series C No. 136, para. 78; Case of Almonacid Arellano et al. v. Chile, Preliminary Objections, Merits, Reparations, and Costs, Judgment of September 26, 2006, Series C No. 154, para. 150; and Case of the La Rochela Massacre v. Colombia, Merits, Reparations, and Costs, Judgment of May 11, 2007, Series C No. 163, para. 147. 227 I/A Court H. R., Case of Cantoral Huamaní and García Santa Cruz v. Peru, Preliminary Objection, Merits, Reparations, and Costs, Judgment of July 10, 2007, Series C No. 167, para. 130; Case of the Massacre of Pueblo Bello v. Colombia, Judgment of January 31, 2006, Series C No. 140, para. 120; and Case of Huilca Tecse v. Peru, Judgment of March 3, 2005, Series C, No. 121, para. 66. 228 IACHR, Second Report on the Situation of Human Rights Defenders in the Americas, December 31, 2011, para. 237. Available at: http://www.oas.org/es/cidh/defensores/docs/pdf/defensores2011.pdf. 229 I/A Court H. R., Case of Valle Jaramillo et al. v. Colombia, Merits, Reparations, and Costs, Judgment of November 27, 2008, Series C No. 192, para. 96. 230 IACHR, Second Report on the Situation of Human Rights Defenders in the Americas, December 31, 2011, para. 232. Available at: http://www.oas.org/es/cidh/defensores/docs/pdf/defensores2011.pdf. 231 I/A Court H. R., Case of Kawas Fernández v. Honduras, Merits, Reparations, and Costs, Judgment of April 3, 2009, Series C No. 196, para. 101. 232 I/A Court H. R., Case of García Prieto et al. v. El Salvador, Preliminary Objections, Merits, Reparations, and Costs, Judgment of November 20, 2007, Series C No. 168, para. 101. 233 I/A Court H. R., Case of the Gómez Paquiyauri Brothers v. Peru, Judgment of July 8, 2004, Series C No. 110, para. 146; and I/A Court H. R., Case of Cantoral Huamaní and García Santa Cruz v. Peru, Judgment of July 10, 2007, Series C No. 167, para. 130. 27