because they did not have the financial resources to, at least, reconstruct the property they had lost or recover their decent living conditions.” The representatives also observed that “the looting and destruction were carried out by State agents who, as of December 14, 1998, exercised the military control of the area” and that “the International Red Cross went to the area that day and verified the presence of members of the National Army in the village.” 254. For its part, the State argued that no causal relationship exists between the State’s actions and the damage to property and belongings in Santo Domingo, and that the perpetrators of the acts and the damage to property were the members of the FARC who entered the village of Santo Domingo causing damage to the property of the civilian population. It added that, as could be observed in the video evidence, “six minutes after the launch of the bomb, the roofs of the houses remained intact [and that,] consequently, it cannot be asserted that the destruction of the houses was caused by the explosive device launched from the air.” In addition, the State argued that “there is no evidence to prove with the required scientific rigor that the Armed Forces carried out acts of pillage, [and that] this is based, principally, on the ruling of the Attorney General’s Office, an entity that acquitted the members of the Armed Forces of the supposed material damage caused.” Lastly, it indicated that, both the video of December 16, 1998, and the video of December 28, 1998, reveal the presence in the village of Santo Domingo of members of the FARC and that they constitute evidence proving that the said armed group entered the houses to loot them. B. Considerations of the Court B.1. Freedom of movement and residence 255. This Court has indicated in its case law that the right to freedom of movement and residence established in Article 22(1) of the Convention is an essential condition for the free development of the individual.367 In this regard, by an evolutive interpretation of Article 22 of the Convention, taking into account the applicable norms of interpretation and in accordance with Article 29(b) thereof, the Court has considered that this provision also protects the right not to be displaced forcibly within a State Party to the Convention.368 256. The Guiding Principles on Internal Displacement issued by the Representative of the Secretary-General of the United Nations in 1998,369 based on international human rights law and international humanitarian law, are of particular relevance for the instant case. The Court considers that several of the guidelines allow the content and scope of Article 22 of the Convention to be incorporated into the context of internal forced displacement. 257. In the instant case, the Commission and the representatives argued that the State had violated the said provision because the inhabitants of Santo Domingo were forced to displace within the municipality or the region. 258. The Skymaster video presented as evidence by the State reveals that the displacement began during the early hours of the morning.370 The video shows several villagers walking on the main highway from the village of Santo Domingo in the direction of Tame. Likewise, in this video, it is possible to observe that the displacement increased as of 10 a.m., following the launch of the 367 Cf. Case of the Massacres of El Mozote and nearby places v. El Salvador, para. 186; Case of Ricardo Canese v. Paraguay. Merits, reparations and costs. Judgment of August 31, 2004. Series C No. 111, para. 115, and Case of the Ituango Massacres v. Colombia, para. 206. Similarly see, United Nations, Human Rights Committee, General comment No. 27 of 2 November 1999, paras. 1, 4, 5 and 19. 368 Cf. Case of the Mapiripán Massacre v. Colombia. Merits, reparations and costs, para. 188, and Case of the Massacres of Río Negro v. Guatemala, para. 172. 369 Cf. United Nations, Report of the Representative of the Secretary-General, Mr. Francis M. Deng, submitted pursuant to resolution 1997/39 of the Commission on Human Rights, Guiding Principles on Internal Displacement, E/CN.4/1998/53/Add.2 of February 11, 1998. 370 Cf. Skymaster video of December 13, 1998 (07:21 a.m.; 07:38 a.m.; 07:42 a.m.; 08:39 a.m.; 09:16 a.m. to 09:36 a.m.; 09:49 a.m.), recording the operation carried out by the Air Force (evidence file, tome 19, folio 9621). ‐ 75 ‐    

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