98 Arguments of the Commission and the parties 327. The Commission requested that the Court order the State to make adequate material and moral reparation to the victims, taking into account the special condition of the seven children, including fair compensation. 328. The representatives asked the Court to order the State to pay each of the fifteen forcibly disappeared victims the sum of USD $80,000.00 as compensation for moral damage caused by the violations committed against them, an amount based on the Court’s jurisprudence regarding forced disappearance in the Peruvian State. Likewise, given the serious nature of this crime to the detriment of the children who were victims, they requested that the State be ordered to pay the additional sum of USD $5,000.00 in favor of Yesenia, Miriam and Edith Osnayo Hilario, Wilmer Hilario Carhuapoma, Alex Jorge Hilario and Raúl and Héctor Hilario Guillén. According to the representatives, these amounts should be delivered to the corresponding next of kin in accordance with domestic law on the line of succession. They also requested that the Court order the State to pay the direct next of kin of the disappeared victims the sum of USD $45,000.00 each, for the moral damage caused by the violations committed against their loved ones, as well as to pay the siblings and other indirect relatives of the disappeared victims the sum of USD $15,000.00 each. In the case of family members who are now deceased, these amounts would be delivered to the appropriate persons based on the line of succession. 329. Regarding pecuniary damage, the representatives requested also payment for consequential damage and lost profits. In relation to consequential damage, they pointed out that members of the Hilario Quispe and Hilario Guillén families lost their respective houses, together with 450 alpacas, 300 head of sheep, 15 horses and 19 cows, as well as foodstuffs consisting of corn, barley, potatoes and others, all of which were stolen by Army personnel. On this point, since the victims did not have documents proving the value of their properties or the expenses incurred, they requested that the Court set an amount in equity. Regarding loss of earnings, they argued that, owing to the interruption of the daily activities of the victims and their families, as a result of what happened, there was loss of income. Therefore, they requested that the State pay a total sum of USD $1,042,072.90. This amount takes into account the age of the victims at the time of their death, the minimum working age in Peru (14 years, historically), average life expectancy in Peru at the time of the victims’ death (67 years), minimum wage series in Peru from the year of the first death to the present, series of the variation of the exchange rate between soles and dollars, and the capitalization of previous periods and discounting of future values. 330. The State expressed its disagreement since it considered that the amounts requested for pecuniary and non-pecuniary damage to be excessive. It pointed out that the purpose of the interAmerican system is to protect human rights and not to profit from them. With regard to consequential damages, it argued that “international responsibility on the part of the Peruvian State has not been proven with respect to the facts denounced in the present case, in terms of the impairment of property and the expenses that this may have entailed.” In its final arguments, the State asked the Court not to order the payment of additional reparations in accordance with the principle of complementarity of the inter-American system, since reparations were already ordered both through the domestic courts and through the Comprehensive Reparations Plan (PIR), - and in some cases were granted - in favor of the relatives (legal heirs) of the victims of the events in the community of Santa Bárbara on July 4, 1991. 331. In this regard, the State explained that, by virtue of the procedures established by Law No. 28592, the regulatory framework of the Comprehensive Reparations Plan (PIR) for victims of violence during the period from 1980 to 2000, was based on the conclusions and recommendations of the CVR Report. Under these provisions, the 15 persons presented as alleged victims of forced disappearance have been officially recognized as victims by the Peruvian Reparations Council (CR) and are therefore registered in the respective Single Registry of Victims (RUV). Likewise, several