35 association by Consuelo García-Santa Cruz was directly related to the trade union demands of the miners and the dissemination of the rights of women miners.101 As a member of the said Women’s Center, she took part in the national mining strikes in 1988. Among other activities, the Center organized literacy courses for the mining women and children; supported community kitchens for the mining families; and promoted health care activities for them.102 144. Article 16(1) of the Convention establishes that those who are subject to the jurisdiction of the States Parties have the right to associate freely with other persons, without the intervention of the public authorities limiting or obstructing the exercise of this right. In addition, they have the right and the freedom to associate in order to seek together a lawful purpose, without pressure or interference that can alter or denature this purpose.103 In addition to these negative obligations, freedom of association also gives rise to positive obligations, such as to prevent attacks on it, to protect those who exercise it, and to investigate violations. These positive obligations must be adopted, even in the sphere of relations between individuals, if the case merits it.104 As it has determined in other cases, the Court considers that the sphere of protection of Article 16(1) includes the exercise of the right to organize trade unions .105 145. The ILO Committee on Freedom of Association has stated that some trade union rights cannot be exercised when impunity exists in situations of trade union violence characterized, inter alia, by extrajudicial executions.106 146. The State must guarantee that people can freely exercise their freedom of association without fear that they will be subjected to any violence; otherwise, the ability of groups to organize themselves to protect their interests could be reduced.107 It is worth noting that when examining a complaint against Peru (supra para. 57), which included the report on the execution of Saúl Cantoral-Huamaní and Consuelo García-Santa Cruz, the ILO Committee on Freedom of Association considered that an environment of violence constituted a grave obstacle for the exercise of freedom of association.108 Freedom of association can only be exercised in a situation in which the fundamental human rights are fully respected and guaranteed, in particular the right to life and safety.109 The Court underscores the State’s obligation to investigate crimes against union leaders effectively and with due diligence, bearing in mind that the failure to investigate such facts has an 101 Cf. testimony given by Rosa Amelia García-Santa Cruz widow of Valverde during the public hearing held before the Inter-American Court on January 23 and 24, 2007; newspaper article entitled “Fuerza and ternura” published in the magazine “Sí” of the week of February 20 to 27, 1989 (file of preliminary exception, merits, reparations and costs, page 922); newspaper article entitled “Testigo puede identificar a los asesinos” published in the newspaper, “Diario La República” on February 15, 1989 (file of appendixes to the application, appendix 1(1), page 138). 102 Cf. testimony given by Rosa Amelia García-Santa Cruz widow of Valverde during the public hearing held before the Inter-American Court on January 23 and 24, 2007; newspaper article entitled “2,000 policías a la caza de los asesinos” published in the newspaper, “Diario La República” on February 15, 1989 (file of appendixes to the application, appendix 1(1), page 140); newspaper article entitled “Consuelo García fue asesinada” published in “Doble Jornada” on March 6, 1989 (file of appendixes to the application, appendix 1(1), page 201). 103 Cf. Case of Baena-Ricardo et al. v. Panama. Judgment of February 2, 2001. Series C. No. 72, para. 156. Cf. also Case of Huilca-Tecse v. Peru, supra note 94, para. 69. 104 Cf. Case of Huilca-Tecse v. Peru, supra note 94, para. 76. 105 Cf. Case of Huilca-Tecse v. Peru, supra note 94, para. 77. 106 Cf. Report of the Committee on Freedom of Association of the International Labour Organization, No. 337 with regard to Colombia, supra para. 48, paras. 535 and 539. 107 Cf. Case of Huilca-Tecse v. Peru, supra note 94, para. 77. 108 Cf. Report of the Committee on Freedom of Association of the International Labour Organization, No. 278 with regard to Perú, supra para. 48, para. 237. 109 Cf. Case of Huilca-Tecse v. Peru, supra note 94, para. 75.