terrorism is presented before the Inter-American Court. Remember that, a decade ago, in the case of Loayza Tamayo versus Peru (Judgment of 09.17.1997), in its assessment of the evidence, the Court had already taken note of that pointed out by the respondent State “with regard to terrorism”, which led, - in its evaluation, - to “an escalation of violence in detriment of human rights. The Court warned, however, that “exceptional circumstances” could not be invoked “in detriment of human rights.” And it added that "None of the provisions of the American Convention may be interpreted in such a way as to allow States Parties or any group or person to suppress the enjoyment or exercise of recognized rights or to restrict them to a greater extent than is provided therein (Article 29(2). The origin of this precept is to be found as far back as the 1948 Universal Declaration of Human Rights (Article 30)." (para. 44) 76. In the same case of Loayza Tamayo, with regard to the merits, the Court once again warned that "Any use of force that is not strictly necessary to ensure proper behavior on the part of the detainee constitutes an assault on the dignity of the person (…), in violation of Article 5 of the American Convention. The exigencies of the investigation and the undeniable difficulties encountered in the anti-terrorist struggle must not be allowed to restrict the protection of a person's right to physical integrity." (para. 57) 77. Actually, when interpreting and applying the American Convention, as corresponds to it, in relation to the specific cases submitted to its knowledge, the Inter-American Court has on reiterated occasions stated the primacy of Law, integrity, and safeguarding of the protected rights, even in the most difficult circumstances, such as, v.g., that of the fight against terrorism. Thus, in the case of Cantoral Benavides versus Peru (Judgment of 08.18.2000), for example, the Court reiterated that “the needs of the investigation and the undeniable difficulties of the fight against terrorism must not lead to restrictions to the protection of a person’s right to humane treatment." (para. 96) 78. In the same manner, in the case of Maritza Urrutia versus Guatemala (Judgment of 11.27.2003), the Court once again warned that "The prohibition of torture is absolute and non-derogable, even in the most difficult circumstances, such a war, the threat of war, the fight against terrorism, and any other crime, martial law or state of emergency, civil war or commotion, suspension of constitutional guarantees, internal political instability, or any other public disaster or emergency." (para. 89) 79. The Court reiterated this warning ipsis literis in the cases of the Gómez Paquiyauri Brothers (Judgment of 07.08.2004, para. 111), and of Lori Berenson (Judgment of 11.25.2004, para. 100), both regarding Peru, as well as in the case of Tibi versus Ecuador (Judgment of 09.08.2004), in which it also stated that “there is an international juridical regime of absolute prohibition of all the forms of torture, both physical and psychological, regime that currently belongs to the sphere of the jus cogens (para. 143). Still regarding the subject in examination, in my Concurring Opinion in the case of the Mapiripán Massacre versus Colombia (Judgment of 09.15.2005), I allowed myself to consider that 22