20 died, the Governor was Mr. Ángel Quitumbo Dagua and the name of Germán Escué Zapata does not appear in the documents as member of the Cabildo. The name of the victim appears in the Cabildo’s composition for the year 1986.65 Furthermore, the State submitted two statements received in the domestic court, of Mr. Ángel Quitumbo Dagua. In the first of such statements it was mentioned that Germán Escué occupied the position of Secretary and Deputy Governor of the Cabildo in the year 1987,66 whereas in the second one, it was pointed out that “yes, I heard that a Zapata has been killed”, who “I know [...] but did not distinguish very well.”67 Finally, the State referred to the statement of an indigenous who said not to have met Germán Escué.68 58. Nevertheless, even when the formal leadership of the victim is not demonstrated, the evidence furnished in the instant case allows the Court to conclude that the victim exercised, in fact, a leadership within the community he belonged and, apart from having occupied the position of Cabildo in 1986, which is a non-disputed issue, he was in charge of several tasks that the community has assigned to him; among them, it can be mentioned the job in the communal store.69 The active leadership of Germán was evidenced by his personal attitudes and his ability to read, write and do math, as well as the preparation he received for such purpose.70 To such respect, Zamora Patiño, the expert witness, expressed: The members of the Cabildo as well as the leaders, who comply with specific functions in the communities or towns, represent a “collective investment” inasmuch as they have been preparing to take up responsibilities since they were children. It is not a person who appears out of the blue, but a "social accumulation" that has been preparing since he was a child to assume responsibilities with his identity and with knowledge of the principles and values of identities of the community.71 59. However, as it has been previously mentioned, the Commission and the representatives sustained that the motive of the death of Mr. Escué Zapata was linked to his position of leader and to the hope that the whole Community had with respect to the protection of their traditional lands. The State, in return, recognizes that there was a conflict of lands, and it adds that such conflict was between the family of Mr. Escué Zapata and the family of Mr. Edelmiro Ul and that the participation of the Army was the result of a complaint related to possession of firearms. 60. From the testimonies acquired during the domestic proceedings and furnished to this Tribunal as documentary evidence, it is clear that during the ‘80s, the two families, in effect, had several conflicts over land and even that those conflicts resulted in the death of some 65 Cf. Record of appendixes to the answer of the complaint, Exhibit 8, page 1360. 66 Cf. Statement rendered by Ángel Quitumbo Dagua, on May 2, 1988 (record of the Appendixes to the answer of the complaint, Prosecutor’s file, Folder 2, page 2025). 67 Cf. Statement rendered by Ángel Quitumbo Dagua, on June 9, 1999 (record of the Appendixes to the answer of the complaint, Prosecutor’s file, Folder 1, page 1792). 68 Cf. Statement rendered by Mario Henry Cifuentes Ul, on October 23, 2006 (record of the Appendixes to the answer of the complaint, Prosecutor’s file, Folder 6, page 3198). 69 Cf. Statement rendered by Omar Zapata, on January 25, 1996 (record of appendixes to the answer of the complaint, Prosecutor’s file, Folder 1, page 1756); expert opinion rendered by Gloria Lucy Zamora Patiño in the public hearing before the Court held on January 19 and 20, 2007; affidavit rendered by Aldemar Escué Zapata, on January 16, 2007 (records of the merits, Volume III, page 655), and affidavit rendered by Mario Pasu on January 16, 2007 (record of the merits, Volume III, page 644). 70 Cf. Affidavit rendered by Bertha Escué Zapata, January 16, 2007 (records of the merits, Volume III, page 644). 71 Cf. Written summary of the experts' opinion, delivered by Gloria Zamora Patiño Volume III, page 788). (merits of the case,