60 prevention and protection for the civilian population in 1989 that was in a situation of risk that was reasonably predictable regarding paramilitary groups.327 195. In the 2008 judgment of the Case of Valle Jaramillo and others v. Colombia, the Court considered that the State had incurred international responsibility for the extrajudicial killing of the victim in 1998, who had actively denounced the collaboration and acquiescence between paramilitary groups and members of the National Army. It contended that this incident was attributable to the State, although it was perpetrated by paramilitary groups, because the State had not effectively suppressed or settled the situation of risk created by the existence of paramilitary groups and because it had continued to promote their actions thanks to the impunity they benefited from.328 The last judgment issued by the Court on this situation was in the Case of Cepeda Vargas v. Colombia. The Court concluded that the State had incurred international responsibility because of the joint participation of members of the Army and members of one or various paramilitary groups in planning and perpetrating the killing of the victim in 1994.329 196. In the present case, the Commission has been able to prove that there are ties and a joint working relationship between the Self-Defense Forces of Magdalena Medio and the National Army in the area. In this regard, the effects of these ties in terms of attributing responsibility are applicable in the present case. 3. General considerations about forced disappearance 197. The Court has repeated that forced disappearance, whose prohibition has the character of ius cogens, is of a continuous or permanent nature and constitutes a multiple violation of various rights protected by the American Convention.330 Regarding this, the Commission and the Court contends that the offense of forced disappearance places the victim in a situation of complete defenselessness, which is especially severe when it is part of a systematic pattern or practice that is applied or tolerated by the State.331 327 I/A Court H.R., Case of the Rochela Massacre v. Colombia. Merits, Reparations and Costs. Judgment of July 4, 2007. Series C No. 165, paragraph 78. 328 I/A Court H.R., Valle Jaramillo and others v. Colombia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 192, paragraph 92. 329 I/A Court H.R., Case of Cepeda Vargas v. Colombia. Preliminary Objections, Merits, Reparations and Costs. Judgment of May 26, 2010. Series C No. 213, paragraph 114. 330 I/A Court H.R., Case of Radilla Pacheco v. Mexico. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 23, 2009. Series C No. 209, paragraph 139; Case of Goiburú and others v. Paraguay. Merits, Reparations and Costs. Judgment of September 22, 2006. Series C No. 153, paragraph 84; and Case of Tiu Tojín v. Guatemala. Merits, Reparations and Costs. Judgment of November 26, 2008. Series C No. 190, paragraph 91. 331 IACHR, Application before the Inter-American Court, Case No. 11.324, Narciso González et al, Dominican Republic, June 2, 2010, para. 103; Application before the Inter-American Court, Case No. 12.517, Gregoria Herminia Contreras et al, El Salvador, June 28, 2010, para. 131. I/A Court H.R., Case of Radilla Pacheco v. Mexico. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 23, 2009. Series C No. 209, paragraph 114; Case of the Serrano Cruz Brothers v. El Salvador. Merits, Reparations and Costs. Series C No. 120, paragraphs 100-106; Case of Heliodoro Portugal v. Panama. Preliminary Objections, Merits, Reparations and Costs. Series C No. 186, paragraph 118; and Case of Anzualdo Castro v. Peru. Preliminary Objection, Merits, Reparations and Costs. Judgment of September 22, 2009. Series C No. 202, paragraph 59; I/A Court H.R., Valle Jaramillo and others v. Colombia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 192, paragraph 76.