organizations.302 Members of Battalion 3-16, a government battalion funded by the US, conducted enforced disappearances and tortured opposition leaders.303 Paramilitary groups also killed and tortured many suspected members of the political left.304 By 1984, 88 individuals had been murdered, 105 had been forcibly disappeared, 138 had been temporarily disappeared or tortured before being turned over to the courts, and 57 remained political prisoners.305
B. Transitional justice mechanisms in the 1980s i) Special Armed Forces Commission Although the Honduran military continued to retain its supremacy over the civilian government through the rest of the 1980s, Álvarez was dismissed by an internal military coup in 1984.306 A Special Armed Forces Commission was established to investigate the disappearances. The Commission was presented with 112 documented cases, but only presented findings on eight of them, stating that those individuals “were either living in Honduras, or had been deported to their country of origin.”307 Amnesty International criticized the Commission for failing to conduct thorough and impartial investigations, for being composed entirely of members of the military, for basing its findings “largely on interviews with former army officials and members of the dni [Dirreción Nacional de Investigación Criminal – the investigative branch of the Public Security Force],308 some of whom had been named as responsible for the ‘disappearances’ by local human rights groups” and for failing to examine key evidence, including “indications of the existence of secret detention facilities and clandestine burial sites, and much of the evidence put forward by relatives and human rights organizations.”309 ii) The Comisión InterInstitucional de Derechos Humanos (cidh) In 1987, President José Azcona Hoyo created the Inter-Institutional Commission of Human Rights (Comisión InterInstitucional de Derechos Humanos – cidh). The cidh’s mandate included gathering information on the disappearance cases before the Inter-American Court of Human Rights (discussed below) and responding to international criticism of the disappearances and human rights violations.310 Again, Amnesty International criticized the cidh for failing to conduct thorough investigations and for lacking independence from civilian and military authorities.311 iii) National Commissioner for Human Rights The most successful of the investigations into the human rights abuses perpetrated by the Honduran military during the early 1980s was conducted by the first human rights ombudsperson, Leo Valladares. In 1992, President Rafael Leonardo Callejas created the National Commissioner for Human Rights (Comisionado Nacional de los Derechos Humanos – conadeh), giving the Commissioner “absolute independence in the performance of his duties” although not mandating an inquiry into disappearances.312 Valladares, appointed as the first National Commissioner, independently investigated disappearances and produced a report entitled “The Facts Speak for Themselves” (Los Hechos Hablan por sí Mismo) in late 1993. It concluded that the practice of enforced disappearances was “systematic and widespread, particularly between 1982 to 1984,” reporting 179 disappearances carried out by the Honduran military and security forces between 1979 and 1990.313 It also stated that the Honduran political and judicial authorities “tolerated the abuses either by action or omission.”314 43