40. The State takes issue with the Commission’s second finding, contending that “it is not in accordance with international human rights practice”, and making reference to “the constant refusing of the European Rights Commission (sic) to accept a case that has previously been submitted to the ILO Committee of Experts.”20 IV. ANALYSIS OF ADMISSIBILITY A. The Commission’s competence ratione personae, ratione loci, ratione temporis and ratione materiae 41. Upon considering the record before it, the Commission considers that it has the competence ratione personae to entertain the claims in the present petition. Suriname is party to the American Convention, having deposited its instrument of accession thereto on November 12, 1987. The Petitioners have locus standi to submit petitions to the Commission, in accordance with Article 44 of the Convention. The petition identifies as the alleged victims, the Lower Marowijne Peoples, persons, whose rights under the Convention, the State of Suriname is committed to respect and ensure. 42. The Commission has competence ratione loci to take cognizance of this petition, since it alleges violations of rights guaranteed by the American Convention that purportedly occurred in the territory of a State party. 43. Finally, the Commission has competence ratione materiae, since the petition alleges violations of human rights protected by the American Convention. 44. The Commission has competence ratione temporis with respect to the alleged violations that occurred since Suriname acceded to the American Convention, given that the alleged events occurred at a time when the duty to respect and ensure the rights enshrined in the Convention was in force for the State. While the Petitioners have not invoked the American Declaration on the Rights and Duties of Man, the Commission notes that the Charter and the American Declaration became sources of legal obligations upon Suriname becoming a Member State of the OAS upon ratification of the Charter of the OAS on June 08, 1977. From this date, the State of Suriname was bound to respect and ensure the rights and duties enshrined in the American Declaration with respect to any alleged violations of the Declaration that occurred between June 08, 1997 and November 12, 1987, when Suriname ratified the American Convention. The Commission would accordingly have competence ratione temporis under the Declaration with respect to any of alleged violations that occurred within this time frame while the Declaration was in force in regard to Suriname. 45. The Petitioners acknowledge that the establishment of the nature reserves and the issue of some of the individual land titles occurred prior to Suriname’s accession to the American Convention. The Petitioners argue that the consequences of these State actions continue to affect the rights of the alleged victims under the American Convention, as detailed above. Based on certain inter-American and other international human rights jurisprudence on this issue21, the Petitioners contend that the Commission is competent, ratione temporis to examine allegations related to the ongoing consequences of violations that commenced prior to Suriname’s accession to the American Convention. The State has not offered any observations on this issue. Ibid. The Petitioners rely on: I/A Court of H.R. Case of Blake. Preliminary Objections, Judgment of July 2, 1996, Series C No. 27, paras. 33 & 40; I/A Court of H.R., Case of Genie Lacayo. Judgment of January 27, 1995, Series C No. 21, para. 22-26; I/A Court of H.R., Case of Plan de Sanchez Massacre. Reparations. Judgment of November 19, 2004, Series C No. 105; I/A Court of H.R., Case of Alfonso Martin del Campo Dodd. Preliminary Objections, Judgment of September 03, 2004, Series C. No. 113, para. 79; I/A Court of H.R., Case of the Serrano-Cruz Sisters. Preliminary Objections, Judgment of November 23, 2004, Series C, No 118, para. 67; I/A Court of H.R.,Case of Moiwana Village, (cit. supra), paras. 108 and 126. The Petitioners also cite a number of decisions from the European Court of Human Rights, including Papamichalpoulos et al. v Greece, Eur. Ct. H.R., App. No. 14556/89 (1993) (Judgment) (Merits); Agrotexim and others v Greece, Eur. Ct. H.R. App. No. 14807/89 (1995) (Judgment) (Merits). 20 21 9