supposed romantic liaisons with several persons, which were based on the statement of a neighbor and which, in practice, were an invasion of Ms. Gutiérrez's private life without objective evidence to support their continued relevance, particularly in the face of other indicia that pointed to other, stronger theories. Apart from the fact that the authorities centered on a weak hypothesis and groundlessly discarded others, elements were incorporated that lacked any basis or cause whatever, such as the existence of a crime of passion born from jealousy or the risk of HIV infection. 157. In that regard, the Commission believes that in this matter the position of the Court in the case of Véliz Franco v. Guatemala is applicable, in the sense that “gender stereotyping had a negative influence on the investigation of the case, to the extent that the blame for what happened was transferred to the victim and her relatives, closing other possible lines of inquiry into the circumstances of the case and the identity of the perpetrators.”202 158. Based on the foregoing, the Commission concludes that the investigation of the disappearance of Mayra Angelina Gutiérrez was not conducted with a gender-aware approach and that it was colored by stereotypes as to the role and social behavior of women, which constituted a violation of the principle of equality and nondiscrimination in access to justice. 3. Rights to life, juridical personality, humane treatment, and personal liberty (Articles 4, 3, 5, and 7 of the American Convention in connection with Article 1(1) thereof) 3.1 The alleged responsibility of the State for forced disappearance 159. The Court has stated a number of times that forced disappearance, whose prohibition has the character of jus cogens, constitutes a multiple violation of several rights protected by the American Convention, including the rights to life, juridical personality, humane treatment, and personal liberty.203 160. Last, forced disappearance comprises the following concurrent, basic elements: (1) deprivation of liberty; (2) direct involvement of governmental officials or acquiescence thereof; and (3) refusal to acknowledge the deprivation of liberty or to disclose the fate and whereabouts of the person concerned.204 In the context of the inter-American system, that characterization emerges from the InterAmerican Convention on Forced Disappearance of Persons, to which the State of Guatemala has been a party since February 25, 2000.205 Several international instruments, as well as the jurisprudence of international organs and national tribunals coincide with the above definition.206 202 I/A Court H.R., Case of Veliz Franco et al. v. Guatemala. Preliminary Objections, Merits, Reparations and Costs. Judgment of May 19, 2014. Series C No. 277, par. 213. 203 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, par. 139; Case of Goiburú et al. Paraguay. Merits, Reparations and Costs. Judgment of September 22, 2006. Series C No. 153, par. 84; and Case of Tiu Tojín v. Guatemala. Merits, Reparations and Costs. Judgment of September 3, 2012 Series C No. Series C No. 190, par. 91. 204 I/A Court H.R., Case of Gómez Palomino v. Peru. Merits, Reparations and Costs. Judgment of November 22, 2005. Series C No. 136, par. 97; Case of Ticona Estrada et al v. Bolivia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 191, par. 55; and Case of Anzualdo Castro v. Peru. Preliminary Objection, Merits, Reparations and Costs. Judgment of September 22, 2009. Series C No. 202, par. 60. 205 On this point, it should be mentioned that the Court has held that the characteristics of forced disappearance may be inferred from the definition contained in Article III of the Inter-American Convention on Forced Disappearance of Persons, its travaux préparatoires and its preamble and standards. See: 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, par. 140, citing Annual Report of the Inter-American Commission on Human Rights 1987-1988, Chapter V.II. This crime “is permanent because it is committed permanently, rather than instantaneously, and it continues while the person remains disappeared” (OEA/CP-CAJP, Report of the President of the Working Group responsible for examine the draft Inter-American Convention on Forced Disappearance of Persons, doc. OEA/Ser.G/CP/CAJP-925/93 rev.1, January 25, 1994, p. 10) 206 In the context of the inter-American system, see: I/A Court H.R., Case of Gómez Palomino v. Peru. Merits, Reparations and Costs. Judgment of November 22, 2005. Series C No. 136, par. 97; Case of Ticona Estrada et al v. Bolivia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 191, par. 55; and Case of Anzualdo Castro v. Peru. Preliminary Objection, Merits, Reparations and Costs. Judgment of September 22, 2009. Series C No. 202, par. 60. In the framework of European system, see: ECHR Case [continues …] 33