attributed [to state agents].25. Specifically, the Administrative Litigation Division of the Council of State indicated that: Within the above evidentiary framework, the Division finds that in the case under review although the administration can be seen to have FAILED in its surveillance of the detainee, failure of service was not proven, because one of its components, DAMAGE, was not accredited. [...] That being so, everything points to the escape having been planned and carried out ON BEHALF OF AND TO PROTECT THE FOUR TRADE UNIONISTS. If the Division concludes within that framework, it is because LIBERTY was a BENEFIT for them and PRISON was a BURDEN. Accordingly, whoever claims that the outcome was different, bore the burden of truth, that is to say, he or she had to prove that the detainees were free in order for either the security forces or private individuals to wreak vengeance on them.26 4. Report of the National Center for Historical Memory. 72. The Commission notes that in November 2013, the National Center for Historical Memory, a state entity whose purpose is to help achieve comprehensive reparation and establish the truth,27 published its report entitled “Huellas y rostros de la desaparición forzada (1970-2010)” [Traces and Faces of Forced Disappearance (1970-2010)]. That report highlights the case of Mr. Víctor Manuel Isaza Uribe and concludes as follows: The forced disappearance of Víctor Manuel Isaza Uribe vividly illustrates how National Security Doctrine as applied , as well as the paramilitary strategy pursued by the Colombian Armed Forces, along with the demonization of the social and political opposition and the elimination of trade union movements in the 1980s. The failure of ordinary courts to act and the complicity of local public authorities were the principal elements used to ensure impunity in the case of the forced disappearance of Víctor Manuel Isaza Uribe. The position taken by the State in the processing of the case before the Inter-American Commission on Human Rights is an example of denial (negacionismo).28 73. The Commission does not have any information to the effect that, in response to that report and its conclusions, the State has taken steps to investigate. C. Relevant contextual data 74. In light of the facts thus far established, the Commission deems it relevant to take certain contextual data regarding how paramilitary groups operated in the area; the risks run by trade unionists at that particular time and place; and the risks run by persons with ties to the Unión Patriótica party. 25 Appendix. Decision handed down in the appeal against the judgment of the Administrative Court of Antioquia on November 26, 1993. Council of State, Administrative Litigation Division, Unit Three . Santa Fé de Bogotá, September 23, 1994. Pages 97 and 104. Appendix to the comments of the petitioners dated August 4, 1995. 26Appendix. Decision handed down in the appeal against the judgment of the Administrative Court of Antioquia on November 26, 1993. Council of State, Administrative Litigation Division, Unit Three . Santa Fé de Bogotá, September 23, 1994. Page 104. Appended to a writ submitted by the petitioners on August 4, 1995. 27 http://www.centrodememoriahistorica.gov.co/somos-cnmh/que-es-el-centro-nacional-de-memoria-historica. Huellas y Rostros de la Desaparición Forzada (1970-2010). Volume II National Center for Historical Memory. Case 4. Víctor Manuel Isaza Uribe: Desaparición Forzada y Represión Antisindical. Available at: http://www.centrodememoriahistorica.gov.co/micrositios/desaparicionForzada/libros-tomo2.html. 28

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