the properties to be expropriated was a plot of 60 hectares, designated Nº 108, which was the property of Mr. Guillermo Salvador Tobar, the father of the petitioners. This extensive property is also known as “Batán of Merizalde,” and now forms part of the Metropolitan Park. Mr. Salvador Tobar is dead and Ms. Maria Salvador Chiriboga and Mr. Guillermo Salvador Chiriboga are his heirs. In reaction to the administrative act taken, some of the affected landowners appealed the decision to the Ministry of Government, pursuant to Article 253 of the Law of Municipal Regimes. Six years later, on September 16, 1997, the Ministry issued “Ministerial Agreement 408” annulling the decision to declare the property to be in the public utility. Two days thereafter, the same Ministry issued “Ministerial Agreement 417” rendering without effect the previous agreement. The petitioners have filed numerous law suits, some of which are still pending, but all of which have the same purpose, namely, to have the Ministerial Agreement 417 declared illegal and the Ministerial Agreement 408 declared valid, annulling the decision to declare their property to be of public utility. 11. On May 11, 1994 the petitioners filed a claim for a “subjective or full jurisdiction” remedy (recurso subjetivo o de plena jurisdicción) with the First District Administrative Court against the former Municipality of Quito (now the Municipality of the Metropolitan District of Quito) for having declared the property of Guillermo Salvador Tobar, as well as others, to be of public utility, although he had died by that time and was, therefore, not the owner of the property. The claim was also based on the State’s failure to comply with certain legal requirements in declaring the property to be of public utility, including the failure to apply several provisions contained in the Public Procurement Law, its Regulations, and the Law on Financial Administration and Control, as well as on failure to notify the petitioners of the administrative ruling. 12. On June 7, 1997, the Municipality took control over the property and began felling trees. Park employees advised the petitioners that they could not access their property because the Municipality was making some necessary modifications. The Municipality brought suit (No. 13000-96) against the petitioners, before the Judge of the Ninth Civil Law Court in Quito, for expropriation of the property. On November 4, 1997, the Judge revoked the ruling on admissibility of the suit in the aforementioned case, due to the State’s failure to comply with the certain requisites set forth in the Constitution and in Article 42 of the Public Procurement Law. Consequently, the authorization to immediately occupy the property and the declaration of the property to be of public utility, were overturned. The petitioners state that despite this judicial decision in their favor, the Municipality continues to occupy the property. 13. In spite of the fact that the Municipality has arbitrarily deprived the petitioners of the use and enjoyment of their property, the Municipality continues to assess taxes on it from the petitioners. 14 The petitioners point out that among the other properties that were included in the statement of May 13, 1991 declaring the property to be of public utility, a plot known as “Urban Market” and today known as “The Gardens of Batán”, was authorized for development and today buildings have been constructed on it. This development was built on land belonging to the Isaías Mahuad family and the petitioners note that since August 10, 1992, Dr. Jamil Mahuad has been the Mayor of the Municipality of Quito. Consequently, the petitioners requested authorization to develop a portion of their property, and this request was denied. On January 12, 1995, the petitioners filed a “subjective or full jurisdiction” claim with the First District Administrative Court against the Council of the Metropolitan District of Quito and its Mayor, in order to obtain a ruling annulling the administrative act of the Planning and Nomenclature Commission of September 7, 1994, which contains a report opposing the request to build on approximately three hectares belonging to the petitioners. At the time of presentation of the instant complaint, the resolution of this suit was still pending. 15. On July 9, 1997, the petitioners filed a claim for the protection of their constitutional rights (recurso de amparo constitucional) with the First District Administrative Court, alleging a violation of rights guaranteed in the Constitution, Article 21 of the American Convention on Human Rights, and in the American Declaration of the Rights and Duties of Man. The First 3