20 56. The Court recalls that alleged victims must be identified in the Merits Report of the Commission, issued in accordance with Article 50 of the Convention. 30 Article 35(1) of the Court’s Rules of Procedure establishes that the case shall be submitted to the Court through the presentation of said report, which must contain “the identification of the alleged victims.” Thus, under this provision, it is for the Commission, and not this Court, to identify precisely and at the proper procedural opportunity, the alleged victims in a case before the Court. 31 Legal certainty requires, as a general rule, that all the alleged victims be duly identified in the Merits Report; thus, it is not possible to add new alleged victims after this stage, except in the exceptional circumstance contemplated in Article 35(2) of the Court’s Rules of Procedure. 32 57. On the other hand, the Court recalls that, in accordance with Article 35(2) of the Rules of Procedure, “[w]hen it has not been possible to identify one or more of the alleged victims in the facts of the case because it concerns massive or collective violations, the Court shall decide in due course whether to consider those individuals as victims.” In its case law on this matter, the Court has assessed the application of Article 35(2) of the Rules of Procedure based on the particular characteristics of each case, 33 and has emphasized that its purpose is not “to obstruct the proceedings with formalisms but, on the contrary, to align the definition provided in the judgment with the rightful need for justice.” 34 Thus, the Court has applied Article 35(2) in massive or collective cases in which there are difficulties in identifying or contacting all the alleged victims, for example, due to situations of armed conflict, 35 displacement, 36 or the burning of the bodies of the alleged victims, 37 or in cases where entire families have disappeared, and there is no one to speak for them. 38 It has also taken into account the difficulty of accessing the area where the events occurred, 39 the lack of records regarding the local inhabitants 40 and the passage of time, 41 as well as particular characteristics of the alleged victims, for example, when 30 Cf. Case of Barrios Family v. Venezuela. Merits, reparations and costs. Judgment of 24 November 2011. Series C No. 237, footnote 214, and Case of Cruz Sánchez et al. v. Peru, supra, para. 62. 31 Cf. Case of the Ituango Massacres v. Colombia. Preliminary objection, merits, reparations and costs. Judgment of 1 July 2006. Series C No. 148, para. 98, and Case of Cruz Sánchez et al. v. Peru, supra, para. 62. 32 Mutatis mutandi, Case Radilla Pacheco v. Mexico. Preliminary objections, merits, reparations and costs. Judgment of 23 November 2009. Series C No. 209, para. 110, and Case of the Human Rights Defender et al. v. Guatemala, supra, para. 47. 33 It should be noted that the Court has applied Article 35(2) of its Rules of Procedure in the following cases: Case of the Río Negro Massacres v. Guatemala. Preliminary objection, merits, reparations and costs. Judgment of September 4, 2012 Series C No. 250; Case of Nadege Dorzema et al. v. Dominican Republic. Merits, reparations and costs. Judgment of 24 October 2012. Series C No. 251; Case of the Massacres of El Mozote and Nearby Places v. El Salvador. Merits, reparations and costs. Judgment of October 25, 2012. Series C No. 252, and Case the Displaced Afrodescendant Communities of the Cacarica River Basin (Operation Génesis) v. Colombia. Preliminary objections, merits, reparations and costs. Judgment of November 20, 2013. Series C No. 270. It has also rejected its application in the following cases: Case of Barbani Duarte et al. v. Uruguay. Merits, reparations and costs. Judgment of October 13, 2011. Series C No. 234; Case of Human Rights Defender et al. v. Guatemala. Preliminary objections, merits, reparations and costs. Judgment of August 28, 2014. Series C No. 283; Case of García and Family Members v. Guatemala. Merits, reparations and costs. Judgment of November 29, 2012. Series C No. 258; Case of Suárez Peralta v. Ecuador. Preliminary objections, merits, reparations and costs. Judgment of May 21, 2013. Series C No. 261; Case of J. v. Peru. Preliminary objection, merits, reparations and costs. Judgment of November 27, 2013. Series C No. 275; Case of Rochac Hernández et al. v. El Salvador. Merits, reparations and costs. Judgment of October 14, 2014. Series C No. 285, and Case of Argüelles et al. v. Argentina. Preliminary objections, merits, reparations and costs. Judgment of November 20, 2014. Series C No. 288. 34 Cf. Case of Río Negro Massacres v. Guatemala, supra, para. 49, and Case of the Displaced Afrodescendant Communities of the Cacarica River Basin (Operation Génesis) v. Colombia, supra, para. 41. 35 Cf. Case of Río Negro Massacres v. Guatemala, supra, para. 48, and Case of the Displaced Afrodescendant Communities of the Cacarica River Basin (Operation Génesis) v. Colombia, supra, para. 41. 36 Cf. Case of Nadege Dorzema et al. v. Dominican Republic, supra, para. 30, and Case of Displaced Afrodescendant Communities of the Cacarica River Basin (Operation Génesis) v. Colombia, supra, para. 41. 37 Cf. Case of the Massacres of El Mozote and Nearby Places v. El Salvador, supra, para. 30. 38 Cf. Case of Río Negro Massacres v. Guatemala, supra, para. 48. 39 Cf. Case of the Displaced Afrodescendant Communities of the Cacarica River Basin (Operation Génesis) v. Colombia, supra, para. 41. 40 Cf. Case of the Massacres of El Mozote and Nearby Places v. El Salvador, supra, para. 30, and Case of the Río Negro Massacres v. Guatemala, supra, para. 48. 41 Cf. Case of Río Negro Massacres v. Guatemala, supra, para. 51, and Case the Displaced Afrodescendant Communities of the Cacarica River Basin (Operation Génesis) v. Colombia, supra, para. 41.