“it merely limited itself to detecting possible risk factors for the commission on torture” by “visiting some detention centers” and “not drawing conclusions on the situation of all detention centers” in Mexico. In particular, the State emphasized that the Sub-Committee “did not carry out its study in the state of Guerrero and, even less, in the detention centers to which the alleged victims in this case were sent.” 51. The Court has used several statements by the Committees and other oversight mechanisms of the United Nations System, where pertinent to a particular case. This is related to the merits of each specific case and the Court has no formal restriction on including in the case file information referring to wellknown facts or to matters of public knowledge. For this reason, the Court includes such documents not as supervening evidence but as information considered complementary and useful according to Article 47 of the Rules of Procedure. The Court emphasizes that there was a dispute between the parties in relation to such rulings and will consider the information indicated therein as applicable to this case, taking into account the arguments put forward by the State regarding the content of such documents. VI PRIOR CONSIDERATIONS 1. Facts not included by the Commission in its application 52. The representatives alleged that Messrs. Cabrera y Montiel were “unlawfully and arbitrarily arrested, and later tortured” “due to their activism” in defense of the environment. They emphasized that these attacks “could be nothing other than a reprisal for their environmental activism.” The representatives also pointed out that this reprisal was part of a pattern of attacks against environmentalists and, in particular, against the Civil Association Organization of Environmentalist Peasants of the Sierra de Petatlán and Coyuca de Catalán (Organización de Campesinos Ecologistas de la Sierra de Petatlán y Coyuca de Catalán, hereinafter “the OEPSP”). Consequently, according to the representatives, “the local military units had information about the whereabouts” of Mr. Montiel Flores and his companions. The representatives further indicated that “[t]he way in which the arrest occurred, the physical and mental abuse to which Messrs. Cabrera and Montiel were subjected, their prolonged detention and the lack of information concerning their whereabouts […], caused their families feelings of deep desperation and anguish that continue affecting them to this day.” 53. In its merits report, the Commission, when assessing various allegations made by the representatives in order to determine whether what happened to Messrs. Cabrera and Montiel amounted to a reprisal for their activities in defense of the forests and whether this could be regarded as part of a pattern of similar reprisals and attacks against environmental activists, the Commission “note [d] that the petitioners did not allege violations of the rights enshrined in Articles 13 [freedom of expression], 15 [right of assembly], and 16 [freedom of association] during the admissibility phase.” Therefore, in its petition, the Commission only mentioned that in 1998 Messrs. Cabrera and Montiel, together with other peasants, established the OEPSP “in order to stop logging operations in the forests of the mountains of Guerrero which, in their opinion, threaten[ed] the environment and the livelihood of local peasant communities.” 54. The State argued that the Commission “never refer[red] to acts of harassment against members of [the OEPSP]” and that “[t]his issue was never mentioned in the [Commission’s] report” and “nor was it mentioned by the 21

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