117 A) PECUNIARY DAMAGE Pleadings of the Commission 247. With respect to the estimate of pecuniary damage, the Commission alleged that, to fairly estimate the lost income in accordance with the needs and circumstances of this case, the Court must take into account the following factors: a) Myrna Mack Chang was a renowned professional, both at a national and international level, in the field of social anthropology. She pursued graduate studies in England, which was uncommon for a Latin American woman in the early 1980s and in terms of Guatemalan reality. The victim was also the co-founder of AVANCSO and she attended numerous international conferences. The Court must take this background information into account, as when the State arbitrarily deprived Myrna Mack Chang of her life, she had before her an enormous potential in terms of the possibilities to continue carrying out her research activities, as well as a wide range of professional opportunities; and b) to estimate the “lost earnings” it is necessary to take into account the average of what the victim earned at the time of the facts and the monthly salaries earned today by various professionals with the academic qualifications, experience and international reputation that Myrna Mack Chang had attained. To this it is necessary to add the interest to compensate for devaluation of the currency in the past, up to the date of payment; there should be a deduction for the sum of future losses of present value, as well as a 25% deduction for personal consumption. Pleadings of the representatives of the next of kin of the victim 248. The representatives of the next of kin of the victim asked the Court to order the State to pay the “lost earnings” of the victim, for which they pointed out that: a) to estimate the lost earnings, the Court should take into account that when she was murdered, the victim was an outstanding professional and intellectual, both in her country and in international circles, for which reason she had many professional opportunities before her; b) to estimate the non-earned salary of Myrna Mack Chang, the Court can base its calculations on the average of what she earned at the time of the facts, what the director of AVANCSO earns today, and the salary earned by persons in Guatemala with similar academic credentials employed in the field of social science. In the course of over ten years, Myrna Mack Chang’s salary would have increased due to length of service, rising cost of living, and inflation in Guatemala; c) to estimate lost earnings in this case, they requested that the Court accept the calculation made by the expert witness offered before the Court, which adds up to US$949,434.78 (nine hundred forty-nine thousand four hundred and thirty-four United States dollars and seventy-eight cents). In a subsidiary manner, they requested that an appropriate calculation be made in accordance with the traditional standards of the inter-American system and

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