51 164. Specifically, based on an analysis of the cases of Rodríguez Vera et al. (Disappeared of the Palace of Justice), 186 Ibsen Cárdenas and Ibsen Peña, 187 La Cantuta, 188Gómez Palomino, 189 19 Merchants, 190 Bámaca Velásquez 191 and Castillo Páez, 192 the element that characterized the act as a forced disappearance was precisely the actions taken by the State agents after killing the victims: that is, measures aimed at hiding what had really happened or erasing all traces of the bodies to prevent their identification or to prevent their fate and whereabouts from being established. 193 The Court considered that Carlos Horacio Urán was executed while in the custody of State agents, that his body was undressed and washed, probably to hide what had really happened, and that the forced disappearance ceased when his remains were identified. Cf. Case of Rodríguez Vera et al. (Disappeared of the Palace of Justice) v. Colombia, supra, paras. 367 to 369. 187 The Court declared the forced disappearance of Rainer Ibsen Cárdenas, who was detained and later taken to the Achocalla detention center, in the city of La Paz. He was deprived of his liberty for approximately nine months, after which he was killed as a result of several shots to the skull, all while in the custody of the State. The forced disappearance ceased when his remains were identified in 2008. The Court reached this conclusion notwithstanding the existence of evidence proving the death of Mr. Rainer Ibsen Cárdenas; however, the Court considered of special relevance “the existence of various irregularities of origin that prevented [it] from reaching the conviction that the remains of Rainer Ibsen Cárdenas were found in 1983, as alleged by the State.” Cf. Case of Ibsen Cárdenas and Ibsen Peña v. Bolivia. Merits, reparations and costs. Judgment of September 1, 2010. Series C No. 217, paras. 80 and 81, 84 to 88, 92 and 94. 188 The Court considered that with respect to the victims of forced disappearance, "the discovery of other human remains and the recognition of objects belonging to some of the detained persons found in [...] clandestine graves would suggest that Armando Amaro Cóndor, Juan Gabriel Mariños Figueroa, Robert Teodoro Espinoza and Heráclides Pablo Meza were also killed. Without prejudice to the foregoing, the Court considered that, until the whereabouts of these persons had been determined, or their remains had been duly located and identified, the appropriate legal treatment for the situation of these four persons [was] that of forced disappearance of persons, as in the cases of Dora Oyague Fierro, Marcelino Rosales Cárdenas, Felipe Flores Chipana and Hugo Muñoz Sánchez”. Cf. Case of La Cantuta v. Peru. Merits, reparations and costs. Judgment of November 29, 2006. Series C No. 162, paras. 114 and 116. 189 The Court declared the forced disappearance of Santiago Fortunato Gómez Palomino. In this regard, it considered as proven that in the course of the investigation by the Specialized Provincial Prosecutor's Office of Lima, a statement was obtained from a person who availed himself of the law of effective collaboration, "who declared that he had witnessed the manner in which the disappearance and execution of Santiago Gómez Palomino took place and indicated the place where his remains were buried at La Chira beach.” Cf. Case of Gómez Palomino v. Peru, supra, paras. 54.14 and 54.15. 190 The Court concluded that members of a “paramilitary” or criminal group that operated with the support and collaboration of members of law enforcement bodies detained and murdered the 19 tradesmen, dismembered their bodies and threw them into the waters of a stream, so that they would disappear and not be found or identified, which is what happened. The Court declared the forced disappearance of the victims more than sixteen years after the facts had occurred, without their remains having been found or identified. Cf. Case of 19 Merchants v. Colombia. Merits, reparations and costs. Judgment of July 5, 2004. Series C No. 109, paras. 138 and 155. 191 The Court found that Efraín Bámaca Velásquez was captured and detained by the Army, constituting a case of forced disappearance. It considered that, “the circumstances in which the detention by State agents of Bámaca Velásquez occurred, the victim's condition as a guerrilla commander, the State practice of forced disappearances and extrajudicial executions” and “the passage of eight years and eight months since he was captured, without any more news of him, cause the Court to presume that Bámaca Velásquez was executed.” The Court also noted that several judicial remedies were attempted in this case to identify the whereabouts of Bámaca Velásquez. “Not only were these remedies ineffective but, furthermore, high-level State agents exercised direct actions against them in order to prevent them from having positive results. These obstructions were particularly evident with regard to the many exhumation procedures that were attempted; to date, these have not made it possible to identify the remains of Efraín Bámaca Velásquez.” Cf. Case of Bámaca Velásquez v. Guatemala. Merits. Judgment of November 25, 2000. Series C No. 70, paras. 170, 173 and 200. 192 The Court concluded that Ernesto Rafael Castillo Páez was detained and forcibly disappeared by members of the National Police of Peru. It considered that, “it may be concluded that the victim was deprived of his life, given the time that has elapsed since October 21, 1990.” In the proceedings before the inter-American system, the family members of the disappeared victim testified that, according to unofficial information, Mr. Castillo Páez had been killed “and that his remains had been taken to a beach south of Lima and exploded.” During the public hearing on the merits of the case held before the Court on February 6 and 7, 1997, it was stated that “Commandant Juan Carlos Mejía León was the officer responsible for Mr. Castillo Páez’s death” and was the one who reported that “his remains were taken to a beach south of Lima and exploded.” Cf. Case of Castillo Páez v. Peru. Merits. Judgment of November 3, 1997. Series C No. 34, paras. 30 a) and e), and 71. 193 In this regard, the United Nations Working Group on Enforced and Involuntary Disappearances has stated that “a detention followed by an extrajudicial execution constitutes an enforced disappearance in the real sense, provided that such detention or deprivation of liberty was carried out by government agents, of any sector or at any level, or by organized or private groups acting on behalf of or with the direct or indirect support, consent or acquiescence of the Government and who, subsequent to the arrest, or even after the execution has been carried out, refuse to disclose the fate or whereabouts of such persons or to acknowledge that the act was committed at all.” Enforced or Involuntary 186