Report No. 272 (2026) IACHR. Petition No. 15.172 (Colombia)

• Court: Inter-American Comission of Human Rights
• Year: 2025
• Case Type: Friendly Settlements
• Respondent State: Colombia

REPORT No. 272/25

CASE 15.172

REPORT ON FRIENDLY SETTLEMENT

GLORIA LARA AND CHILDREN

COLOMBIA

OEA/Ser.L/V/II

Doc. 287

10 December 2025

Original: Spanish

Approved electronically by the Commission on December 10, 2025.

Cite as: IACHR, Report No. 272/25, C.1., Friendly Settlement, G.L. and children, Colombia, December 10, 2025.

www.cidh.org

REPORT No. 272/25

CASE 15.172

FRIENDLY SETTLEMENT

GLORIA LARA AND CHILDREN

COLOMBIA1

DECEMBER 10, 2025

1. SUMMARY AND RELEVANT PROCEEDINGS OF THE FRIENDLY SETTLEMENT PROCESS

1. On October 18, 2012, the Inter-American Commission on Human Rights (hereinafter “the Commission" or "IACHR") received a petition filed by F.T.E., which was subsequently joined by M.C.E.B.2 and C.A.C.D.,3 (hereinafter "the petitioners") , alleging the international responsibility of the Republic of Colombia (hereinafter "the S." or "the C. S." or "Colombia”) for the violation of the human rights set forth in Articles 5 (humane treatment), 8 (judicial guarantees) and 25 (judicial protection), read in conjunction with articles 1(1) (obligation to respect rights) and 2 (obligation to adopt domestic legal effects) of the American Convention on Human Rights, (hereinafter "the Convention" or "the American Convention"), to the detriment of Gloria L. de E., Héctor Manuel E. L., Gloria Lucía E. L. and Luz María E. L. (hereinafter "alleged victims"), for the alleged impunity surrounding the kidnapping and murder of Gloria L. de E., in 1982, following criminal proceedings that were delayed to the point that the statute of limitations expired, to the benefit of those accused of the crimes committed against her.

2. On December 19, 2022, the Commission issued Admissibility Report No. 373/22, in which it found the petition admissible and found it was competent to hear the claim presented by the petitioner regarding the alleged violation of the rights contained in articles 5 (humane treatment), 8 (judicial guarantees) and 25 (judicial protection) contained in the American Convention, read in conjunction with articles 1(1) and 2 of said instrument.

3. On May 25, 2023, the parties signed a memorandum of understanding to pursue a friendly settlement in which they agreed on timetable for advancing negotiations. On August 30, 2023, the Commission notified the parties of the formal start of the friendly settlement procedure, and over the following months, the parties held bilateral meetings to discuss the reparation measures to be included in the friendly settlement agreement (hereinafter “FSA” or “agreement”). T. agreement was signed on December 12, 2023, in the city of Bogota D.C.

4. On December 3, 2024, the parties signed an addendum, partially modifying the content of the FSA. Subsequently, on December 11, 2024, the parties submitted a joint report on the progress made in the compliance with the FSA and requested its approval by the IACHR.

5. In this friendly settlement report, pursuant to Article 49 of the Convention and Article 40.5 of the Rules of Procedure of the Commission, a summary of the facts alleged by the petitioners is provided and the friendly settlement agreement, signed on December 12, 2023, by the petitioners and representatives of the C. S., is transcribed. L., the agreement signed between the parties is approved, and the publication of this report in the IACHR Annual Report to the General Assembly of the Organization of American S.s is resolved.

2. THE FACTS ALLEGED

6. The petitioners alleged the international responsibility of the C. S. for the presumed impunity surrounding the kidnapping and subsequent murder of Ms. Gloria L. de E., which occurred in 1982, as a result of a criminal proceeding whose delays would have led to the statute of limitations on criminal prosecution, thereby favoring the alleged perpetrators of the crimes committed against her.

7. According to the petitioners’ account, Ms. Gloria L. de E. was a political activist and public official affiliated with the Liberal Party, having served as Colombia’s ambassador to the United Nations, National Director of Communal Action and Indigenous Affairs, and Director of Community Integration and Development at the Ministry of Government. As background, they would have indicated that in 1970 an armed group known as the “People’s Revolutionary Organization (ORP)” was formed, whose objective would have been to combat the bourgeois class, considered an enemy of the peasantry. T. group would have resorted to kidnapping and extortion as means of financing and political pressure.

8. In relation to the events that would have led to Ms. L.’s death, the petitioners stated that on J. 23, 1982, while serving as Director of Community Integration and Development at the Ministry of Government, she would have been intercepted and kidnapped by several armed individuals while traveling in her official vehicle. They affirmed that criminal investigating judges and the Judicial Police carried out various investigative procedures in an attempt to rescue her. N., on November 28, 1982, her body would have been found covered with a blanket marked with the initials ORP.

9. F. the information contained in the case file, it would appear that the criminal proceedings against the alleged perpetrators of the kidnapping and murder of Ms. Gloria L. de E. were marked by multiple procedural stages, including the initiation of investigations, the imposition and subsequent revocation of preventive detention measures, reopenings and temporary dismissals, as well as contradictory decisions among various judicial instances. A. in 1992 the National Tribunal would have issued convictions against several defendants, in 1998 the Supreme C. of Justice would have declared the termination of proceedings due to the expiration of the statute of limitations. Subsequently, in 2010, an attempt would have been made to reopen the case through a request for review, arguing that the acts constituted crimes against humanity; however, such request would have been dismissed in 2012, on the grounds that the elements of such crimes were not deemed to have been established, thereby consolidating a state of alleged impunity.

3. FRIENDLY SETTLEMENT

10. On December 12, 2023, in the city of Bogotá D.C., the parties signed a friendly settlement agreement. Its text reads as follows:

FRIENDLY SETTLEMENT AGREEMENT

CASE 15.172 H.M.E.L.E. AL.

On December 12, 2023, in the city of Bogotá D.C., Ana María Ordoñez Puentes, Director of International Legal Defense of the National Agency for the Legal Defense of the S., acting on behalf of and representing the C. S., hereinafter the "C. S.”; and on the other hand, attorney María Carolina Estepa Becerra, representing the victims; jointly referred to as "the parties", who hereby sign this Friendly Settlement Agreement in Case No. 15.172. H.M.E.L. et al., filed before the Inter-American Commission on Human Rights.

PART ONE: DEFINITIONS

For the purposes of this Agreement, the following terms shall apply:

IACHR or Inter-American Commission: Inter-American Commission on Human Rights.

Moral damages: H. effects of the facts of the case that are not of an economic or financial nature, that result in pain, affliction, sadness, anguish, and anxiety felt by the victims.

Material damage: Involves the loss of, or detriment to, the income of the victims, the expenses incurred as a result of the events and the consequences of a pecuniary nature that have a causal nexus with the facts of the case.4

Non-material damage: Includes both the distress and suffering caused to the victims, the impairment of core values of the persons concerned, and changes of a non-pecuniary nature in the living conditions of the victims or their family.5

S. or C. S.: In accordance with Public International Law, it shall be understood as the signatory to the American Convention on Human Rights, hereinafter “American Convention” or “ACHR.”

Measures of satisfaction: Non-pecuniary measures that are intended to ensure the recovery of the victims from the harm caused to them.6

Parties: C. S., the representative, and the victim's family.

A. of responsibility: Acceptance of the facts and the human rights violations attributed to the S..

Comprehensive reparations: All measures that objectively and symbolically restore the victim to the state prior to when the damage was committed.

The petitioner: Attorney M.C.E.B.,...