whom they consider beneficiaries of the reparations and, in their brief with final arguments, said representatives also included fourteen next of kin. Arguments of the Commission 50. With respect to this point, the Commission stated that: a) the wishes of the next of kin of the victims, expressed by their representatives, must be an important consideration when reparations are determined to remedy, insofar as possible, the damage resulting from the “massacre” in Las Palmeras and its non-elucidation before domestic courts. The purpose of the requests made by the Commission is to complement those claims. Therefore, it agrees with the arguments of said representatives regarding the grounds for reparations in the instant case, as well as regarding payment of compensation for “moral damage;” b) with respect to attribution of this damage, the expert opinion gives rise to a presumption that the consequences of impunity prevailing in the instant case affect the closest kinship group –parents, children, spouses, and siblings- of the victims who died. Evidence provided regarding eleven of the next of kin of the victims is representative of the emotional situation and the consequences suffered by the kinship groups referred to in the judgment on the merits and which must be applied in connection with all of them; and c) it rejects the standards proposed by the State to determine reparations for denial of justice, as they are not applicable to this case, they are based on domestic legal theses, and they do not fulfill the criteria of the case law of the Court. 51. Likewise, in its brief with final arguments, the Commission submitted the list of persons who, in its opinion, should be deemed entitled to reparations. Arguments of the State 52. The State argued that: a) with respect to the claim of the representatives of the next of kin of the victim that the State should pay monetary compensation to them for the moral damage suffered due to judicial delay and fear of alleged imminence of harm, it believes that compensation for the detriment should be in direct proportion to the magnitude of the damage caused. The right to “prompt and complete justice” cannot be redressed by means of a sum of money, which is only useful to compensate for damage that can be quantified monetarily; b) the State does not deny the generic obligation to compensate for moral damage caused by facts for which it is responsible. Nevertheless, since investigations are still ongoing, the only way to repair the detriment suffered by the next of kin of the victims, which consists of not having received the reply one would expect from prompt and complete administration of justice, is by swiftly and seriously accelerating the proceedings to modify the situation that fosters impunity, instead of ordering the State to pay indemnification. Furthermore, the amounts requested and their distribution among the next of kin are disproportional; and

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