98 means necessary to prevent impunity in the face of violations that affect the human rights of women defenders.479 The investigation into these facts should be conducted mindful of the range of actors involved in the context being examined, and the threat they may pose to the work of women engaged in the defense of human rights. 337. Many of the risks suffered by women who work in the defense of human rights in Colombia are based on the discrimination and stereotypes that women have suffered historically; notions that are challenged by their leadership in areas occupied by the actors in the armed conflict, as observed supra 167-174 in the section on facts proven.480 For a full and comprehensive appreciation of these risks and their link to historic discrimination against women, it is useful to refer not only to the general provisions of the American Convention, but also to the specialized ones included in the Convention of Belém do Pará, as a supplemental instrument of interpretation.481 338. The petitioners’ arguments regarding the guarantees set forth in Articles 8.1 and 25 can be summarized by the failure to act with due diligence of the Colombian State to investigate and punish every perpetrator and intellectual author of the human rights violations perpetrated against Mmes. Rúa, Bastidas, Naranjo, Mosquera, and Yarce, as a result of their work as human rights defenders in Comuna 13. The State, in response, has claimed that it is undertaking several investigations into the aforementioned crimes, and that it has identified and punished several of those responsible. 339. The Commission presents in this section some observations related to the investigations pertaining to the human rights violations analyzed throughout this report, committed to the detriment of the five women human rights defenders who are the subject of this matter, and their next of kin. 1. Criminal investigation into the murder of Ana Teresa Yarce 340. Based on the evidence available to the IACHR, it can be surmised that the investigation undertaken into the killing of Ms. Ana Teresa Yarce has led to the conviction of two members of the paramilitary bloc Héroes de Granada, which was operating in the area at the time of the incidents.482 Mr. Jhon Jairo Cano Durán has been convicted for the crimes of Murder of a Protected Person, retaliation, forced displacement, and simple conspiracy to commit a crime, in confessing to the murder of Mrs. Yarce.483 According to information provided by the State as part of the provisional measures 479 IACHR, Report on the Merits No. 54/01, Maria Da Penha Fernandes (Brazil), April 16, 2001, para. 56. 480 IACHR, Access to Justice for Women Victims of Violence in the Americas, OEA/Ser. L/V/II. doc.68, January 20, 2007, 481 IACHR, Access to Justice for Women Victims of Violence in the Americas, OEA/Ser. L/V/II. doc.68, January 20, 2007, para. 32. para. 32. 482 Note DIDHD/GOI No. 77119/2954 from the Colombian State, November 15, 2012, pp. 56-57; Annexes 44, 47 and 75-76. Defendant’s Voluntary Initial Statement of Jhon Jairo Cano Duran, October 19, 2007; Defendant’s Voluntary Initial Statement of Jorge Enrique Aguilar Rodríguez, August 23, 2007; Decision on the Bail Status of Jorge Enrique Aguilar, Office of the Attorney General of the Nation, File: 2169, August 31, 2007; Decision on the Bail Status of Jhon Jairo Cano Durán, Office of the Attorney General of the Nation, File: 2169, September 6, 2007. Criminal proceeding on the murder of Mrs. Ana Teresa Yarce. 483 th Annex 81. 4 Specialized Circuit Court of Criminal Matters, Medellin, Early Disposition [Guilty Plea], Jhon Jairo Cano Durán, Murder of a Protected Person, Forced Displacement, Retaliation and Conspiracy to Commit a Crime, January 9, 2009. Criminal proceeding on the murder of Mrs. Ana Teresa Yarce. Annex 1. Observations of the Petitioners in reference to the matter of Miryam Eugenia Rúa Figueroa et al – Case 12.595 dated May 3, 2012.