22 argues that certain land titles and long-term leases were issued before it acceded to the American Convention, so it cannot be held liable for those actions. As explained in the Admissibility Report, all three Nature Reserves were established before Suriname’s accession to the American Convention, and Suriname similarly contends that this means it cannot be held liable for acts and omissions related to the establishment of the Reserves, as these took place before it acceded to the Convention. The State also claims that since the mining concession was granted before Suriname’s accession to the American Convention, Article 21 “is therefore not applicable to granting of the concession (with or without consultation), nor to its status over time but possibly only to effects of activities carried out pursuant to the concession on the right of Article 21 of the Convention.”128 As explained in the Admissibility Report, at the admissibility stage Suriname did not submit any arguments related to the Commission’s jurisdiction ratione temporis in this case, and the Commission already decided in that Report that it has jurisdiction ratione temporis over the violations alleged by the petitioners “insofar as these events may be of a continuing nature”129. The IACHR recalls that the proper procedural stage to submit arguments about admissibility and jurisdiction is the admissibility stage before the IACHR. This way, in that stage the IACHR can make a determination regarding jurisdiction and admissibility based on the available information. Without prejudice to the foregoing, given that Suriname has repeatedly submitted arguments related to jurisdiction ratione remporis at the merits stage, and that in this specific case the continuity of some acts, omissions and their effects is intrinsically related to the merits of the case, the Commission addresses the State’s arguments in this regard below. 72. 73. As indicated in the Admissibility Report, the OAS Charter and the American Declaration of the Rights and Duties of Man (“American Declaration”) became sources of legal obligations for Suriname once it became a Member State of the OAS, on June 8, 1977, and as of that date Suriname has had a continuing obligation to respect and guarantee the rights and duties enshrined in those instruments.130 74. In addition, the Inter-American Court and the IACHR have consistently applied the international law principle that a State is generally not liable for acts or omissions that were consummated prior to its ratification of a treaty.131 However, it is also a principle of international law that if prior acts, or the effects of such prior acts or omissions, continue after the date of a State’s ratification of or accession to the relevant treaty, the State can be internationally liable for violating that treaty.132 Thus, if the effects of Suriname’s issuance of land titles, the establishment of the Nature Reserves, and the granting of the mining concession before November 12, 1987 (the date of Suriname’s accession to the American Convention) on the rights of the Kaliña and Lokono Peoples continued after that date, Suriname can be held liable for the effects caused by those acts after November 12, 1987. 128 Submission of Suriname, September 12, 2008, p. 11. 129 Report No. 76/07, Admissibility, The Kaliña and Lokono Peoples, Suriname, October 15, 2007, para. 48. 130 Report No. 76/07, Admissibility, The Kaliña and Lokono Peoples, Suriname, October 15 ,2007, para. 44. 131 See Admissibility Report, paras. 46-47, n. 22. 132 Admissibility Report, para. 47, n. 22 (citing I/A Court H.R., Case of Blake. Preliminary Objections. Judgment of July 2, 1996. Series C No. 27; I/A Court H.R., Case of Cantos. Preliminary Objections. Judgment of September 7, 2001. Series C No. 85; I/A Court H.R., Case of Alfonso Martín del Campo-Dodd. Preliminary Objections. Judgment of September 3, 2004. Series C No. 113; I/A Court H.R., Case of Almonacid-Arellano et al. Preliminary Objections, Merits, Reparations and Costs. Judgment of September 26, 2006. Series C No. 154; IACHR Report N° 74/90 Case 9850, Hector Geronimo Lopez Aurelli, Argentina, 4 October 1990.).