104. Regarding the rights violated, forced disappearance breaches the right to personal liberty and places the victim in a grave situation of risk of suffering from irreparable harm to his or his rights to personal integrity and life. The Court has indicated that forced disappearance violates the right to humane treatment since “the mere subjection of an individual to prolonged isolation and deprivation of communication is in itself cruel and inhuman treatment.”110 The Commission and the Court have established that it is evident that victims of this practice feel violated in all dimensions of their personal integrity.111 The Court has also indicated that, even if incidents of torture and deprivation of the life of the person victim of a disappearance cannot be proven in a concrete case, subjection of those detained to state agents or to individuals who act with their acquiescence or tolerance and who practice torture and killing with impunity represents, in itself, an infringement of the rights to personal integrity and life.112 105. According to the case law of both bodies of the inter-American system, the practice of disappearances has frequently involved the secret execution of those detained, without trial, followed by concealment of the corpse in order to eliminate any material evidence of the crime and to ensure absolute impunity, which entails a brutal violation of the right to life, established in Article 4 of the Convention.113 Case law has also established that the fact that a person is missing for a long period of time and in a context of violence it is a reasonable presumption to conclude that the person was killed.114 106. In addition, the Commission has consistently pointed out that, in cases of forced disappearance, with respect to the multiple and complex nature of this grave human rights violation, its execution creates a specific violation of the right to recognition as a person before the law.115 That is how the Inter-American Court has also recognized it.116 This is because the disappeared person can no longer enjoy and exercise the rights to which he or she is entitled and forced disappearance is “not only one of the most serious forms of placing the person outside the protection of the law but it also entails denying that person’s existence and to place him or her in a kind of limbo or uncertain legal situation before the society, the State.”117 The Commission considers that forced disappearance also involves a violation of the rights to a fair trial and judicial guarantees regarding the missing person, in terms of the absence of actions to search for his or her whereabouts by means of efficient investigations and the impossibility of filing remedies in his or her favor because of the state’s denial of the incident in its custody.118 107. In the case of the Santa Bárbara Campesino Community v. Peru, the Court recapitulated its case law regarding forced disappearance, specifically in cases where the legal qualification of the incidents as such occurred because of “[…] what state agents did after they killed the victims, that is, the adoption of measures aimed at concealing what had really happened or erasing all traces of the bodies to prevent their identification I/A Court H.R. Case of Anzualdo Castro v. Peru. Preliminary Objection, Merits, Reparations, and Costs. Judgment of September 22, 2009. Series C No. 202, para. 85. 111 I/A Court H.R. Case of Ticona Estrada et al. v. Bolivia. Merits, Reparations, and Costs. Judgment of November 27, 2008. Series C No. 191, para. 58; and IACHR, Report No. 5/16, Cases 11.053, 11.054, 12.224, 12.225, and 12.823. Merits. Peru. April 13, 2016, para. 167. 112 I/A Court H.R. Case of Ticona Estrada v. Bolivia. Merits, Reparations, and Costs. Judgment of November 27, 2008. Series C No. 191, para. 59; and Case of Radilla Pacheco v. Mexico. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 23, 2009. Series C No. 209, para. 154. 113 I/A Court H.R. Case of 19 Merchants. Judgment of July 5, 2004. Series C No. 109, para.154; and IACHR, Report No. 44/00. Case 10.820. Américo Zavala Martínez. Peru. April 13, 2000, para. 41. 114 I/A Court H.R. Case of Velásquez Rodríguez. Judgment of July 29, 1988. Series C No. 4, para. 188; and IACHR. Application lodged before the Inter-American Court. Case No. 12.529. Rainer Ibsen Cárdenas and José Luís Ibsen Peña v. Bolivia. May 12, 2009, para. 248. 115 IACHR. Applications lodged before the Inter-American Court in the following cases: Renato Ticona Estrada et al. (12.527), paras. 153165; Rosendo Radilla Pacheco (12.511), paras. 138-145; Kenneth Ney Anzualdo Castro (11.385), paras. 167-176; Julia Gómez Lund et al. (11.552), paras. 208-220; Florencio Chitay Nech (12.599), paras. 136-146; Rainer Ibsen Cárdenas and José Luís Ibsen Peña (12.529), paras. 251-262; and Narciso González Medina et al. (11.324), paras. 138-149. 116 I/A Court H.R. Case of Anzualdo Castro v. Peru. Preliminary Objection, Merits, Reparations, and Costs. Judgment of September 22, 2009. Series C No. 202, paras. 91-92; Case of Radilla Pacheco v. Mexico. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 23, 2009. Series C No. 209, para. 157. 117 I/A Court H.R. Case of Anzualdo Castro v. Peru. Preliminary Objection, Merits, Reparations, and Costs. Judgment of September 22, 2009. Series C No. 202, para. 90. See also: IACHR, Report No. 5/16, Cases 11.053, 11.054, 12.224, 12.225, and 12.823. Merits. Peru. April 13, 2016, para. 166. 118 IACHR. Report on the Merits No. 60/18. Case 12.709. Juan Carlos Flores Bedregal and family, Bolivia, May 8, 2018, para. 69. 110