76 365 principles concerning the collective rights of indigenous peoples. In addition, the right to ownership of land has been recognized by the IACHR as one of the rights of indigenous peoples and tribes having a 366 collective aspect. 342. It is based on the collective dimension of the indigenous peoples and tribes that the Commission and Court have recognized that they have a particular relationship with their lands and resources traditionally occupied and used, by virtue of which these lands and resources are considered 367 joint property and enjoyment for the communities, as is the case with the Saramaka tribal peoples. 343. The Court has also established that given the close link between the indigenous peoples and their traditional lands and the natural resources tied to their culture which are found there, these and the intangible elements that emerge from them, must be safeguarded by Article 21 of the American Convention. In this respect, the Court has considered that the term "property" in Article 21, includes "material things which can be possessed, as well as any right which may be part of a person's patrimony; that concept includes all movable and immovable, corporeal and incorporeal elements and any other 368 intangible object capable of having value." 344. The Commission observes that the Afro-descendant communities of Cacarica are made 369 up of tribal peoples, as acknowledged by the Constitutional Court of Colombia. These tribal peoples also maintain a close bond with their land, as part of their ancestral tradition, and therefore both their traditional lands as well as their natural resources must be safeguarded by Article 21 of the American Convention, in their collective dimension. 345. The Commission also takes into consideration that Principle 21 of the Guiding Principles 370 requires due respect and guarantees for the right to the displaced population's property. 346. The Commission observes that the legal battles as to registration, use and enjoyment of the ancestral lands of the Cacarica communities prior to the relevant events of the present report have been regulated and brought to the attention of the domestic courts. Without prejudice to the fact that the petitioners have submitted information in this regard as background and contextual events, thus clarifying the situation, the Commission will examine the potential breach of the right to property envisaged in Article 21 of the American Convention, as a result of the violent events and forced displacement which are relevant to the current analysis. 347. In the present case, the displaced persons, as victims of "Operation Genesis" and of paramilitary raids, have seen the exercise of their right to property affected by the bombardments, ransacking and destruction of their communities. As an example, in the Bijao hamlet the shops, homes and storerooms were looted; they ransacked food, identity documents, jewellery, clothes and money; 365 IACHR, allegations before the I/A Court H.R in the Case of the Mayagna (Sumo) Community Awas Tingini, referred to in the Judgment of August 31, 2001. Series C No. 79, para. 140(ñ). 366 I/A Court H.R., Case of the Mayagna (Sumo) Community Awas Tingini, Judgment of August 31, 2001. Series C No. 79, para. 113 367 I/A Court H.R., Case of Saramaka v. Surinam, Preliminary Objections, Merits, Reparations and Costs, Judgment of November 2007. Series C No. 172, para. 85. IACHR Report No. 40/04, Case 12.053, Mayan Indigenous Communities of the Toledo District, Belize, October 12, 2004, para. 114. I/A Court HR Case of the Mayagna (Sumo) Community Awas Tingini, Judgment of August 31, 2001. Series C No. 79. 368 I/A Court H.R.; Case of the Comunidad de Sawhoyamaxa Community, Judgment of March 29, 2006. Series C No. 146, para. 121. Cf. Case of the Yakye Axa Indigenous Community, Judgment of June 17, 2005. Series C No. 125, para. 137; Case of the Mayagna (Sumo) Community Awas Tingini, Judgment of August 31, 2001. Series C No. 79, para. 144, and Case of Ivcher Bronstein. Judgment of February 6, 2001. Series C No. 74, para. 122. 369 Annex 1. Constitutional Court Judgment T-955/2003 of October 17, 2003, p. 7. Annex 15 to the petitioners’ allegations on the merits received on March 10, 2008. 370 Annex 90. Guiding Principle No.21 of the UN Guiding Principles on Internal Displacement, E/CN.4/ 1998/53/Add.2 of February 11, 1998. Principle 4. See:http://www.un-documents.net/gpid.htm.