67
and caused her forced displacement.303 Nonetheless, in the investigation undertaken by the authorities
into her complaint, it does not appear that the possible involvement of official forces in the occupation
and subsequent dismantling of her home, after her displacement, was explored.
233. The context of insecurity in which these human rights defenders operated is confirmed
by the fact that precautionary measures were granted on October 22, 2004 by the IACHR on behalf of
Mrs. Naranjo and Mosquera as a result of their community organization endeavors, and the Court
granted provisional measures on July 5, 2006. It is important to highlight that both the IACHR and the
Court have repeatedly ruled on the ineffectiveness of the mechanisms of protection provided to the
women human rights defenders in the context of said measures, with some of their next of kin even
being murdered.304
234. The IACHR thus concludes this section expressing its concern over the chilling effect of
the State’s failure to protect, in this instance, the women who work to defend human rights in Comuna
13. Statements from Miryam Eugenia Rúa Figueroa and Luz Dary Ospina Bastidas in the case file
indicate that they were forced to abandon their community and organizational work permanently due to
their fear of accusations, persecution and other acts of violence and, as will be thoroughly discussed
later in this report, they remain in a situation of displacement, in precarious economic circumstances.305
Such declarations also allude to the extension of these violations to the family members of the
mentioned defenders, including having joined the forced displacement, a radical and traumatic change in
their life project, and the interruption of their work and studies, an aspect which will be analyzed in
detail in later sections of this report.306
235. The IACHR reiterates the need to legitimize and protect the actions of women human
rights defenders in the face of the threat to their existence and work by the actors in the Colombian
armed conflict, including the Armed Forces and National Police, and their positive obligation to create
the structural conditions necessary for them to be able to do their work in this known context of risk.
236. Based on the foregoing considerations, the Commission finds that the right to personal
integrity of Miryam Eugenia Rua Figueroa and Luz Dary Ospina Bastidas, as set forth in Article 5.1 of the
American Convention, in connection with Article 1.1 of the same instrument, was violated in the present
case.
303
Annex 16. Complaint to the Office of the Ombudsperson of July 18, 2003, on inter-urban displacement and security
of Luz Dary Ospina B. and her family; Annex 17. Complaint to the Departmental Prosecutor, City of Medellín, July 18, 2003, or
intra-urban displacement and security of Luz Dary Ospina B. and her family.
304
See, for example, IACHR, Press Release, IACHR condemns continued threats and murders directed against human
rights defenders and their families in Colombia, March 7, 2011; Decisions of the Inter-American Court of Human Rights in the
Matter of Mery Naranjo et al – Comuna 13, Colombia September 22, 2006, January 31, 2008; November 25, 2010; and March 4,
2011.
305
Annexes 3 and 15. Statements from Miryam Eugenia Rúa Figueroa and Luz Dary Ospina Bastidas received by the
GIDH addressed to the Inter-American Commission on Human Rights, April 27, 2012.
306
Annexes 3 and 15. Statements from Miryam Eugenia Rúa Figueroa and Luz Dary Ospina Bastidas received by the
GIDH addressed to the Inter-American Commission on Human Rights, April 27, 2012.