8 proceedings and the amparo proceeding in order to verify that they were both executed with full respect for the guarantees of due process of law, providing Mr. Lagos del Campo with the opportunity to appeal any judicial rulings that went against him. e) “Observations on the brief with motions, pleadings and evidence concerning the delimitation of the legal dispute.” The State alleged that the remedies that were not examined in order to establish compliance with the admissibility requirements – in other words, those subsequent to the appeal filed on March 15, 1993 – could not be used to consider violations of additional rights to those contained in the Merits Report. Likewise, it alleged that the presumed victim’s representatives unduly used the events related to the self-coup of April 5, 1992, and the dissolving of the Court of Constitutional Guarantees to substantiate a suggested infringement of the right to contest court decisions, even when those facts were not considered in the Commission’s Merits Report. Consequently, it asked the Court to establish that the arguments presented by the representatives regarding violations of the right to be heard by a judge or court, and the right to contest decisions, as well as the new facts and context mentioned by the representatives, were not considered to be part of the dispute. f) “Undue inclusion of additional presumed victims in the motions and pleadings brief.” The State argued that the presumed victims are those indicated by the Commission in the Merits Report, which, in this case, only considered Mr. Lagos del Campo as a presumed victim. Consequently, the State contested the inclusion of presumed victims by the representatives in whose favor they had requested measures of reparation, because they were not considered in the Commission’s Merits Report. 16. The Commission argued that the allegations: (a) review of the legality with regard to the Commission’s report and (b) failure to exhaust domestic remedies referred to preliminary objections that the State did not present at the proper procedural opportunity and, therefore, should be rejected as time-barred. In addition, it observed that the allegations: (c) inclusion of Article 16 in the Merits Report, and (d) the Commission’s lack of competence to assume a fourth instance role, were not preliminary objections, but rather matters relating to the merits of the matter. Regarding allegation (e) delimitation of the legal dispute, the Commission argued that the facts that the State was trying to exclude by this allegation were included in the factual framework defined by the Commission. Lastly, with regard to argument (f) undue inclusion of presumed victims, the Commission agreed with the State that Mr. Lagos del Campo was the only victim declared in the Merits Report. Meanwhile, the representatives were in general agreement with the Commission’s position. Regarding the inclusion of additional victims, the representatives, in their brief of September 5, 2016, asked the Court to consider that only Mr. Lagos del Campo was a victim. B. Considerations of the Court 17. Bearing in mind the diverse nature of the arguments submitted by the State, and its express assertion that they were not submitted as preliminary objections, but rather as a request for the Court to “review legality” and respond to certain “procedural questions,” the Court recalls that preliminary objections are objections to the admissibility of a petition or to the competence of the Court to hear a specific case or any of its aspects, based on the person, matter, time or place, provided that such considerations are of a preliminary nature. 10 Therefore, regardless of how the State describes them in its briefs, if, on examination, it is determined that the Cf. Case of Las Palmeras v. Colombia. Preliminary objections. Judgment of February 4, 2000. Series C No. 67, para. 34, Case of Zegarra Marín v. Peru. Preliminary objections, merits, reparations and costs. Judgment of February 15, 2017. Series C No. 331, para. 16. 10

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