responsibility.2 The treaty obligations of the States Parties are binding for all branches and organs of the State.3 6. The States Parties to the Convention must ensure compliance with its provisions and their inherent effects (effet utile) within their respective domestic legal systems. This principle applies not only to the substantive provisions of human rights treaties (i.e. those addressing protected rights), but also to procedural provisions, such as those referring to compliance with the Court’s decisions. These obligations should be interpreted and applied in such a manner that the protected guarantee is truly practical and effective, bearing in mind the special nature of human rights treaties.4 7. The States Parties to the American Convention that have accepted the Court’s contentious jurisdiction have a duty to comply with the obligations established by the Court. This includes the duty to inform the Court about the measures it has adopted to comply with the Court’s rulings in its decisions. The State’s prompt observance of its obligation to report to the Court on how it is complying with each of the measures ordered is essential for evaluating the status of compliance with the Judgment as a whole. 5 a) Fourth payment to the victims or heirs who signed the agreements 8. Regarding the fourth and final payment of the amounts established in the agreements, the State reported, inter alia, that “of the 270 former workers and heirs who benefited from [the] Judgment, 265 workers received the payments in September 2011, excepting two (2) persons who did not sign the agreement, one (1) person who has not withdrawn the cheque, one (1) person who died while awaiting the results of the inheritance procedures [...] and [one last beneficiary] who received his full entitlement in previous payments, and therefore the amount due to him was settled prior to the last payment.” Panama forwarded copies of the respective cheques. Moreover, the State reiterated the criteria that were used to determine the amounts of the settlement and explained that the “income tax refund […] was paid by means of the first payment of 2008”. Panama asserted that “it has complied with the proposal submitted to the Inter-American Court of Human Rights in 2008” and requested that this Court “certify its full compliance with the decision in t[he] Judgment of February 2, 2001.” 9. The Center for Justice and International Law reported that “according [to] information from the victims, cheques have been delivered or deposits have been made through guarantee certificates for the fourth and final payment, to all the 2 Cf. International Responsibility for the Promulgation and Enforcement of Laws in Violation of the Convention (Articles 1 and 2 American Convention on Human Rights). Advisory Opinion OC-14/94 of December 9, 1994, Series A Nº.14, para. 35, and Case of Caballero Delgado and Santana v. Colombia. Monitoring Compliance with Judgment. Judgment of the Inter-American Court of Human Rights of February 27, 2012, Considering para. 5. 3 Cf. Case of Castillo Petruzzi et al v. Peru. Monitoring Compliance with Judgment. Order of the InterAmerican Court of Human Rights of November 17, 1999, Considering para. 3 and Case of Caballero Delgado and Santana v. Colombia, supra note 2, Considering para. 5. 4 Cf. Case of Ivcher Bronstein v. Peru. Jurisdiction. Judgment of September 24, 1999, Series C No. 54, Para. 37, and Case of Caballero Delgado and Santana v. Colombia, supra note 2, Considering para. 6. 5 Cf. Case of Barrios Altos v. Peru. Monitoring Compliance with Judgment. Order of the InterAmerican Court of Human Rights of September 22, 2005, Considering para. 7 and Case of Kawas Fernández v. Honduras, supra note 1, Considering para. 3. 3

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