Jose Luis Figueroa/ Admissibility Hearing April 29, 2010/Held at Vancouver, British Columbia

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ADMISSIBILITY HEARING

IMMIGRATION DIVISION

IMMIGRATION AND REFUGEE PROTECTION DIVISION

APRIL 29, 2010

Vancouver, B.C.

DA9-01353/14-04-2010

BETWEEN:

MINISTER OF PUBLIC SAFETY AND

EMERGENCY PREPAREDNESS

AND

MR. LUIS FIGUEROA

BOARD MEMBER OTTO NUPPONEN

KARL KELLER APPEARING FOR MR. FIGUEROA;

SANDRA TERAN APPEARING FOR THE MINISTER

SPANISH INTERPRETER: SARA TAYLOR.



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PRESIDING MEMBER:

This is the continuation of an immigration

admissibility hearing, conducted at Vancouver, British

Columbia, on the 29th of April, 2010. My name is Otto

Nupponen. I am a member of the Immigration Division of

the Immigration and Refugee Board of Canada. This hearing

once again concerns Jose Luis Figueroa, who is present in

person. The Minister’s counsel continues as Sandra Teran.

Lay counsel for Mr. Figueroa continues as Karl Keller. As

well, we have Sarah Taylor who continues on a standby

basis as a Spanish interpreter.

So, we reconvene today for Mr. Figueroa’s

submissions. I note that he has provided documentary

disclosure to myself and to the Minister’s counsel in

accordance with the time suggestions that were made at the

last sitting on April 14th. So, perhaps, we enter the --

Mr. Figueroa’s disclosures as Exhibits, first, Ms. Teran?

MS. TERAN:

Sure.

PRESIDING MEMBER:

So, there are six books, A through F. The

First book A, will be entered as Exhibit P-1, book B will

be entered as Exhibit P-2, book C will be entered as

Exhibit P-3, book D will be entered as Exhibit P-4, book E

will be entered as Exhibit P-5, and final book F is

entered as Exhibit P-6.

(MR. FIGUEROA’S BOOK A MARKED AS EXHIBIT P-1)



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(MR. FIGUEROA’S BOOK B MARKED AS EXHIBIT P-2)

(MR. FIGUEROA’S BOOK C MARKED AS EXHIBIT P-3)

(MR. FIGUEROA’S BOOK D MARKED AS EXHIBIT P-4)

(MR. FIGUEROA’S BOOK E MARKED AS EXHIBIT P-5)

(MR. FIGUEROA’S BOOK F MARKED AS EXHIBIT P-6)

MR. FIGUEROA:

Your Honor, we put a cover letter along

with this one, and we put a link to a website where there

are about 200 homilies of Monsignor Romero. By the time I

needed to incorporate some of these homilies, I needed to

go through all of those. So I just introduced the

website, but we have 3 homilies that we would like to

introduce as exhibits as well. So. And we will present

these copies to you.

PRESIDING MEMBER:

Okay. And homilies are what?

MR. FIGUEROA:

Those are sermons that --

PRESIDING MEMBER:

Sermons. Okay. Okay, will enter three

sermons as well. You give copies to Ms. Teran.

MR. FIGUEROA:

And these are for her.

PRESIDING MEMBER:

So, we’ll enter the three homilies namely:

“First Sunday of Lent”, “Sixth Sunday of Ordinary Time”

and “Fifth Sunday of Lent” all together as Exhibits P-7



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MR. FIGUEROA:

So, those will be: P 8, 9 and 10?

PRESIDING MEMBER:

No, collect together P-7.

MR. FIGUEROA:

Ok. P-8.

PRESIDING MEMBER:

P-7

MR. FIGUEROA:

I have F as P-7.

MS. TERAN:

No.

PRESIDING MEMBER:

There were six books, correct?

MR. FIGUEROA:

Yeah, What was for F?

PRESIDING MEMBER:

Book F is P-6

MR. FIGUEROA:

P-6

PRESIDING MEMBER:

So, the homilies are P-7.

MR. FIGUEROA:

Okay.

(THREE HOMILIES, “FIRST SUNDAY OF LENT”, SIXTH SUNDAY OF

ORDINARY TIME” AND “FIFTH SUNDAY OF LENT” MARKED AS

EXHIBIT P-7)



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PRESIDING MEMBER:

First time I’ve entered homilies as

evidence.

MR. FIGUEROA:

They are.

PRESIDING MEMBER:

I’m sorry, Ms. Teran?

MS. TERAN:

There’s always the first.

REV. KELLER:

As a clergyman, are you surprised?

PRESIDING MEMBER:

Well, ultimately, I will need to determine

the relevance of all the documents presented. So we’ll

see what relevance things will have.

So we are convened today for Mr.

Figueroa’s submissions. So, I’m not sure, Mr. Keller are

you providing submissions, or is Mr. Figueroa?

REV. KELLER:

Yes, yes, I am.

PRESIDING MEMBER:

You are. Okay. We’ll begin with your

submissions.

REV. KELLER:

Okay. I would like to ask Ms. Teran some

questions first as she asked him as well. Is that, okay?

PRESIDING MEMBER:



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Yes.

REV. KELLER:

Okay.

PRESIDING MEMBER:

So, you are asking Mr. Figueroa questions.

MR. FIGUEROA:

No, Ms. Teran.

REV. KELLER:

I am asking Ms Teran. She had asked him

some questions at the beginning. And now, I would like to

ask her some questions. Is that possible?

PRESIDING MEMBER:

Well, Ms. Teran is counsel. She is not a

witness. Witnesses are generally questioned.

REV. KELLER:

Okay.

PRESIDING MEMBER:

Counsel aren’t generally questioned,

because they are not witnesses. They are not providing

evidence. I don’t know --

MR. FIGUEROA:

Your Honour, I think that these questions

-- I think that they are kind of relevant, that they need

to be answered before we present the submissions because

all our evidence will be depending on her answers to

these. And as the Minister representative -- as the

Minister’s representative, she should be able to answer



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these questions. They are simple questions. They are yes

or no questions.

PRESIDING MEMBER:

What do the questions deal with generally?

REV. KELLER:

Well, for example: What I wanted to ask,

is the Minister of the opinion that the government of El

Salvador during the armed struggle from 1980 to 1992 is an

organization that there are reasonable grounds to believe

is or was engaged in terrorism?

PRESIDING MEMBER:

Well, Ms. Teran has provided evidence and

submissions as to the government how the allegation works.

It seems to me that you are trying to get her to express

some sort of opinion on behalf of the government of

Canada. Somehow you are asking her to provide evidence

here and she is not here to provide evidence.

MR. FIGUEROA:

Well, but the thing is that the government

Canada has some opinion about El Salvador. They have

already manifested through different cases their opinion

about FMLN. They have stated that FMLN is an organization

that was engaged in terrorism. So, therefore they should

be able to answer on these questions. Because the

government of Canada has relations with El Salvador.


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Otherwise we would need to subpoena the Minister’s opinion

on this matter. These are essential questions for us to

submit -- in order to present our case.

PRESIDING MEMBER:

Well, the Minister’s counsel has provided

evidence and submissions alleging that the FMLN was

engaged in terrorism. That’s the allegation, right?

REV. KELLER:

Mm-hmm. Mm-hmm.

PRESIDING MEMBER:

That’s what she has provided evidence and

submissions on. That’s what this hearing is about.

REV. KELLER:

Okay. That’s what we need to present is

that they aren’t terrorists.

PRESIDING MEMBER:

If you have evidence and submissions to

refute what she’s told us, that’s what you need to give

us.

MR. FIGUEROA:

Okay.

PRESIDING MEMBER:

If you are asking for some opinions,

background opinions by the government of Canada on that, I

am afraid, I don’t see that is relevant. What you need to

do is address the evidence and submissions that Ms. Teran

has given us.


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MR. FIGUEROA:

Then we can ask these questions in between

when we make our submissions.

PRESIDING MEMBER:

It may well be that that’s the way to bring

the issue up. the question why certain things may be --

MR. FIGUEROA:

Okay, we have to explain that. Okay.

Thank you.

SUBMISSIONS BY REV. KELLER:

Okay. What I would like to do is to

begin in 1977, to just give a picture of the situation of

El Salvador at that time. And that’s why the homilies

were provided so that we can understand why the rising of

the FMLN came in to be. And it was in 1977 that Priest

Grande had been killed and it was in 1977 that the

Archbishop Romero was ordained to be the Archbishop of El

Salvador, and at that time was not involved in political

events. However when his friend Priest Grande was killed,

who did speak about the atrocities that were happening in

El Salvador at the time, then he began to speak against

this atrocities and could not be silent on what he saw.

And he shared all of this on his homilies on radio.

And it was in February of 1980 then, that

the station was bombed and I will mention that a little

later. But in this homilies, which he had about 200 of

them, that were given on radio and therefore not just


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through El Salvador, but through Latin America, and this

was not appreciated by the government --being able to

share what was happening. And It was Archbishop Romero’s

to stand by the needs and the best interests of the poor

in El Salvador. Basically putting him in constant clash

with the government in power, and the sectors of the

Salvadoran society, who saw on his sermons the danger of

their economic interests. And it was at this time then,

we have noted that this atrocities were happening and --

during the decade of the ‘70s, and specially in the period

that we have evidence from the homilies from 1977,

February, when the Archbishop was ordained. And also to

note that these events of human rights violations happened

before the FMLN was created. And so, I would like to the

homily of Archbishop Romero, just the day before he was

murdered by the death squads on March 24. So if we look

on homily March 23 -- is where on page 17 homily, March

23.

PRESIDING MEMBER:

I’ll point for the record, there’s some

highlighting in my copy of the homily. Do you have

highlighting in yours, Ms. Teran?

MS. TERAN:

Yes, I do.

REV. KELLER:

Okay. 23 -- page 17.

And it is there that he -- I’m going to go


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to page 12, I believe, first where there is a letter to

President Carter. That is on --

MR. FIGUEROA:

February 17th.

REV. KELLER:

I’m sorry. Homily February the 17. He

wrote a letter to President Carter to describing the

situation --

PRESIDING MEMBER:

In what page? I’m sorry, what page?

REV. KELLER:

Page 12 --

PRESIDING MEMBER:

February 17, page 12.

REV. KELLER:

And he writes:

“I am rather concerned to hear that the US

government is considering ways to promote arms

race in El Salvador by sending military

equipment, and advisors to train three

batallions – Salvadorans – in logistics,

communications and intelligence. If it true,

this newspaper report, the contribution of the

government, rather than promoting greater

justice and peace in El Salvador, certainly

exasperates injustice and repression against

the organized people, who often have been


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fighting for their rights, and our respected

most basic human.”

Some of the English doesn’t come out quite exactly as it

was translated from the Spanish.

“The current board of governors and specially

the armed forces and security forces have

unfortunately not demonstrated its ability

resolve in political practice and structurally,

the serious national problems. In general,

only has resorted to repressive violence,

causing loss of life and injuries much higher

than recent past military regimes seem

systematically.

Human rights violations was reported by

the same American Commission on Human Rights.

The brutal way that security forces recently

ousted and killed the occupants of the

headquarters of the Christian Democrats, even

though the board of governors and the party

seems did not authorize the operation, is

evidence that the Board and the Christian

Democrats is not governing the country, but the

political power in the hands of unscrupulous

military, that the only thing they do is

supress the people and promote the interests of

the Salvadoran oligarchy.

If it is true that last November, a group


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of six Americans was in San Salvador and

thousands of dollars were provided in gas masks

and protective vests and instructed on its used

against demonstrations. You should know that

it is clear since the security forces more

effective personal protection, and have even

more fiercely repressed the people using deadly

weapons.

Therefore, as the Salvadoran Archbishop of

the Archdiocese of San Salvador, I have an

obligation insure that prevail justice and

faith in my country. I ask you, if you really

want to defend human rights, then prohibit the

military aid…”

He’s asking to prohibit military aid to the Salvadoran

government.

“…ensure that your government is not directly

or indirectly involved with military pressure,

economic, diplomatic, and so on. And we are

currently experiencing serious economic and

political crisis in our country, but its

increasing fear that the people what has

raising awareness, and the organization that

has begun train for the manage and responsible

for the future of Salvador and the only one

capable for the outcoming of this crisis.”

And ultimately he signs this but he’s demonstrating over


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and over again the terrible suffering and in the last line

he says:

“I hope that the religious feelings and

sensitivity for the defence of human rights

will move you to accept my request thereby

avoiding further bloodshed in this country.”

And what has been suffered in that country. That was his

comments to share of what was happening at that particular

time.

February the 24th, on the homily of the

24th, pages 2 to 4 --

MR. FIGUEROA:

I don’t think that they have that one.

REV. KELLER:

Oh, they don’t have that one?

MR. FIGUEROA:

No, no, no. That one --

REV. KELLER:

Sorry, it happen to be when a bomb was

placed, in the radio station to silence Archbishop

Romero’s homilies that he was sharing as well as well as

sharing -- during these homilies he would share what was

happening in El Salvador and the repression to the people.

And as a result since that radio station came back on, it

was then that he was murdered by the death squads on March

24 and silenced then from that time.

It was after his death that the FMLN was


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formed in October of 1980. He was murdered in March 24 --

and also to say the importance of that date, even though

it is 20 years ago -- still this past March 24th that is a

special day of remembrance in El Salvador, because of the

death the Archbishop at that time. Different

organizations have used all means, but the tyranny would

not, at this point, even listen to a priest. And

therefore, as result of what was happening, the FMLN was

formed in October of 1980.

In Volume -- that’s P-1, tab 3, page 1.

If you go to tab 3 page 1. The governments of France and

Mexico made a declaration --that would be in August 28,

1981, concerning the situation in El Salvador. These two

governments considered conditions of injustice and

repression of the Salvadoran people, that what they were

enduring -- they recognized that the alliance of the FMLN

with the FDR as a representative political force and it

says:

“We recognize that the alliance of the…”

This is paragraph 1, 2, 3, 4.

“We recognize that the alliance of this

liberation front is a representative political

force ready to assume the obligations and

rights that flow from them.”

And later on, on the Truth Report it does speak of the

president of the country going to Europe to get support

for El Salvador, and that was in July of 1984. He visited


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with the president Mitterrand of France, and he declined

to modify or reject the declaration.

I want to just add at this time, too, Mr.

Figueroa was a student in school at this time and many

times from his own personal experience, the school would

be ordered by the government forces to vacate all with

their hands on their heads. And a great deal of fear was

put upon them. And the reason I mention this is simply,

because of the atrocities that were happening, and were

being heard of, the murder especially of priests and so on

--t hat it would be that this young mind was formed, “How

can I support this kind of government?” And therefore,

looking towards organization whereby he might be able to

help to bring peace to this country.

MR. FIGUEROA:

Just for the record, Your Honor, Pastor,

he mentioned the visit from the president of El Salvador,

who was Napoleon Duarte at that time, is mentioned on the

Commission on Truth. But that’s a report that is from a

website about the El Salvador relationships.

In July 1984, Napoleon Duarte, who was the

president of El Salvador went into Europe in order to get

some economic support from different governments. He went

to England, Germany, and one of his main objectives was

going into France, and he asked the president of France,

Francois Mitterrand to refute the declaration that their

government have done with conjunction with the government


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of Mexico regarding FMLN. And at that time Francois

Mitterrand declined to make any changes on that

declaration. That’s three years after the war started.

So just for the record, I just wanted to

clarify that part.

REV. KELLER:

Some of the evidence that was given by the

Minister were books -- information from books written by

Americans. Since the American government was involved in

El Salvador in support of the government, it is my view

that, obviously, some of these books were rather prejudice

on how they also were written from the information that

they had received.

So at this time, I would like to look at P-

3. At P-3, which is the United Nations Truth Commission,

and on page 5 of that commission, about halfway down,

there’s Volume 1, and it talks about reports of the

forensic investigation, and therefore, I just want to

point out that I believe that the United Nations who put

this report together, therefore had expert scientists, who

also uncovered the truth, using forensic information, and

there were specialists appointed by the United Nations,

trained in this particular field, to be able to bring out

the truth of what was happening in El Salvador, or what

happened in El Salvador at this time.

Then, on page 7, the UN agreed that there

was a number of regimented acts. It says that there were


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a number of repugnant acts taking place. Right at the

middle of the page, the first paragraph:

“In response to this situation, the negotiators

agreed that such repugnant acts should be

referred to a Commission on Truth.”

And that is why this document was made. On page 8 --

pardon me -- on page 10, it talks in the middle of the

page, ” Phenomenology of Violence”:

“It is a universality accepted premise that

the individual is the subject of any criminal

situations since humans alone possess the will

and can therefore take decisions based on will.

It is individuals that commit crimes, not

institutions they have created. As a result,

it is to individuals and not their institutions

that the corresponding penalties established by

law must be applied.

However, there could be some situations in

which the repetitions of acts in time and space

would seem to contradict the above premise. A

situation of repeated criminal acts may arise

in which different individuals act within the

same institution in unmistakably similar ways

independent of the political ideology of

governments and decision makers. This is

reason to believe that institutions may indeed

commit crimes if the same behavior becomes a


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constant in the institution, and specially if

clearcut accusations are met with a cover up by

the institution to which the accused belong and

the institution is slow to act when

investigations reveal who is responsible. In

such circumstances, it is easy to succumb to

the argument that repeated crimes mean that the

institution is to blame.”

Then on page 19 of the Truth Report, about

a little more than halfway down in 1,2,3,4, 5. The fifth

paragraph about in the middle, paragraph 8-B it says:

“Gave the Commission the power to review

freely in private any individuals, groups, or

members of organizations, or institutions.”

And lastly in the 4th Preamble, Paragraph of mandate:

“The parties agreed that the task entrusted to

the Commission should be filled through a

procedure that is both reliable and

expeditious.”

And I think that the word I really want to emphasize is

that this Truth Commission was done by the United Nations

was reliable.

On page 21, where states about in the

middle of the page, number 1, 2 and 3:

“Overwhelming evidence, conclusive or highly

convincing evidence to support the commission’s

findings; substantial evidence, very solid


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evidence to support the Commission’s findings;

and sufficient evidence, more evidence to

support the Commission’s findings than to

contradict it.”

So this is the information that we wish to present then.

On page 22, in the middle of the paragraph,

well, there are a number, that the Commission believe that

there were no alternatives, but name names in those

paragraphs at that point, and the fact that it name names

only when it was absolutely convinced by the evidence and

therefore names were given as to even who committed the

crimes, as we will discover a little later that we

mentioned. The Commission refers to terrorism only

referring to the death squads.

When the Minister gave the report it always

referred to the FMLN as a terrorist organization. The

Commission did not refer to the FMLN in any of its entire

report that the FMLN was a terrorist organization. It was

an opposition political party as the Franco-Mexican

declaration declared. But they do refer to terrorism when

they are referring to the death squads of the government.

And that is about – 1, 2, 3, 4 – the fifth line from the

bottom of page 23, where “the organized terrorism in the

form of the so called death squads”.

On page 25, to just go back to the

situation which they bring out on the Truth Report, that

during the funeral a bomb went off outside San Salvador.


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This is the funeral of Archbishop Romero, pardon me.

“The panic-stricken crowd, estimated at 50,000

people was machined gunned, leaving an

estimated 27 to 40 people dead and more than

200 wounded.”

You will notice on the next paragraph, that:

“On May 7 of 1980, Major D’Aubuisson was

arrested on a farm, along with a group of

civilians and soldiers. In the raid, a

significant quantity of weapons and documents

were found implicating the group in the

organization and financing of death squads

allegedly involved in Archbishop Romero’s

murder. The arrest triggered a wave of

terrorist threats and institutional pressures,

which culminated in D’aubuisson’s release.

This strengthen the most conservative sector in

the government, and was a clear example

passivity and inertia in the judiciary during

this period.”

And obviously they just felt that they needed to release

this man, who was responsible and he is named as the one

responsible for the murder.

And then during 12 and 15 August a general

strike was called by the FDR, a coalition of center-left

parties and was violently suppressed leaving 129 people

dead. And then on November, six FDR leaders were


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abducted. Their bodies were found later, bearing signs of

torture. A few days later, Hernandez Martinez issued a

communicate claiming responsibility for these killings.

And then in the very last paragraph:

“In late 1980, as a change of administration

was taking place in the United States. The

violence in El Salvador reached the United

States citizens. On the 2nd of December, 4

church women were arrested, raped, and murdered

by the members of the National Guard. At the

end of the year, Coronel Majano, was removed

from the Junta and Napoleon Duarte became

president.”

Describing some of the events that took place.

If we could then turn to page 26, about the

middle of the page where it says:

“On January 14, the United States

administration restored military aid, which had

been suspended after the murder of the United

States churchwomen. The United States

government also significantly increased its

military economic assistance. The increasing

flow of resources was intended to train,

modernize and expand the structure of the

number of elements of the Armed Forces. The

rapid deployment of infantry battalions,

specializing in anti-guerrilla warfare, also


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began to be created.”

And at the very bottom, it talks about, “This battalion…”

the very last two lines.

“…carried out one of the worst massacres of the

war in various hamlets around El Mozote.”

On the top of page 27, the first paragraph, the last line

that the Christian Legal Aid reported that there were

about 12,501 deaths in 1981. I believe that, we will get

to that section a little later, of that murder.

On page 28, “The violations within the

context of the armed conflict”, and we notice that speaks

of this as a war. Not necessarily as -- the FMLN by the

Minister was always regarded as a guerrilla group. The

Franco-Mexican declaration did not look at this as a

guerrilla group, but as a military -- or an opposition

party that was fighting for the benefits of the people of

El Salvador. And at the bottom two paragraphs of page 28,

it then talks about 5,962 people died at the hands of the

government forces. And in the last paragraph, it talks

about -- starting at the second half line:

“Vice-President Bush…”

that was Vice-President George Bush, the father of the

past president,

“…publicly condemned the death squads. He

demanded the removal of certain armed forces

and security officers who were associated with

human rights violations. This demonstrated the


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United States diplomatic pressure could bring

about the reduction in the number of

violations.”

And then on the top of page 29, it says:

“The FMLN strengthened its structure and

demonstrated strength in the military.

However…”

in the second paragraph, about 5 lines from the bottom,

“…in 1984, there were reported to be 500,000

displaced persons within the country, 245,500

Salvadoran refugees abroad, bringing the total

of the displaced persons to approximately one

and a half million. Following much

international criticism, the armed forces cut

back on the use of air attacks against civilian

population.”

Even the international community recognized that the

government of El Salvador was the perpetrator of against

the people of El Salvador, that was causing so much harm,

that it was their pressure that asked them to cut back on

what they were doing to the population of El Salvador.

And it was not the FMLN that was causing that.

On page 30, you will see that on the bottom

third -- the third paragraph from the bottom:

“On November the 4th, the new ambassador,

Thomas Pickering referred to the pressure being

put on the government of El Salvador to take


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action against the leaders of the death squads,

mentioning…”

and he mentions Hector, chief of the security of the

constituted assembly, and he mentions also Major Pozo, of

intelligence of the treasury police, also Coronel -- he

mentions the number of people there. And as it said

earlier in the report that if there was good evidence

these names would be mentioned.

And the most important event in this

respect was the visit of the Vice-President of the United

States, George Bush to El Salvador on the 9th of December.

Bush took the opportunity to state publicly that the death

squads must disappear because they constituted a threat to

the political stability of the government. Later on, he

handed the government with a list of civilian and military

personnel suspected of belonging to those clandestine

organizations.

It just astounds me that the United States

government who was supporting the government of El

Salvador, recognizing death squads, what the government

was doing, and even in the face of other governments of

the world -- the international community condemning the

government for what was happening, they would continue to

support that government in its struggle against the FMLN.

However, what I am also being able to hopefully describe

here is that isn’t it any wonder then that the FMLN was

formed in order that the people, who are being so


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repressed, would have some place to be able to go, to

bring some force or to join as a force that finally bring

some stability to the country of El Salvador.

Then I would like to move to page 38, on

the top of the page, the 16th of November, 1989, army

murdered the Jesuit priests of the Centro-American

University, and then it mentions further atrocities that

were happening. He mentions the ones that they had. It

mentions the housekeeper and her 15-year-old daughter, as

they murder everything that, I guess, was there at that

time.

And then at this point, I would like to go

over to page 40, because it was -- I got the impression

that as the Minister gave her report that the aggressor in

all of the conflict was the FMLN, that was a terrorist

group, whereas here they call it a war.

PRESIDING MEMBER:

I don’t know if she meant to give that

impression. Her position is to try to explain to me what

the group was about. Her job wasn’t necessarily to point

out what everybody else was doing in the country. It

seems that is your turn now to show what other people was

doing as well--

REV. KELLER:

Okay. Well on page 40, there’s a section

halfway down: “Cases and Patterns of Violence – A General

Overview of Cases of Patterns of Violence,” and the


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Commission on Truth registered more than 22,000 complains

of serious acts of violence that occurred in El Salvador

between January of 1980 and July of 1991.

And then in the third last paragraph from

the bottom: Those giving testimony attributed almost 85

percent of the cases to agents of the State, paramilitary

groups allied to them and the death squads. Armed Forces

personnel were accused in almost 60 percent of the

complaints, members of the security forces in

approximately 25 percent, members of military escorts and

civil defence units in approximately 20 percent, and

members of the death squads in more than 10 percent of the

cases. The complaints registered accused FMLN in

approximately 5 percent of the cases. Therefore it seems

to me that if there were terrorist acts, that’s 5 percent

by the FMLN and 85 percent by the government. They were

17 times more terrorists than the FMLN, as the picture

that was drawn by the United Nations.

There is then in page 41, about third

paragraph from the bottom, roughly 50 percent of all the

complaints analyzed concerned incidents that took place

between the first two years, 1980 and ‘81. More than 20

percent took place in the following two years. In other

words, over 75 percent of the civil war serious cases of

violence reported on the Commission on Truth took place

during the first four years of the decade.

I would like to point out that this was the


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time when Mr. Figueroa was in school, or high school, and

having this kind of reporting on the news day after day,

this would be rather very impressive on a young mind, and

where else would he go? Certainly not to support a

government that had already 85 percent -- or 75 percent of

at this time of all their atrocities. And yet, they were

responsible for 85 percent. I understand the FMLN 5

percent. The other 10 percent that they didn’t quite know.

But what would this do to young student? Obviously, if he

wanted to do something for your country or to help your

country, you would want to support some group that would

be able to bring about some kind of peace to the

repression that was taking place in the country.

On page 43, about the middle of the page,

a summary it says:

“In the early hours of November, six Jesuit

priests, a cook and her 16-year-old daughter

were shot and killed at the pastoral institute

at Jose Simon.”

And others. And there’s criminal proceedings in the next

paragraph were subsequently brought against the members of

the armed forces to the murders and includes these people

who were some of the leaders of the armed forces of the

government.

And I would like to go then to page 49, on

the second of January. This would be about the --there’s

a line close to the bottom, two paragraphs up. On second


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January 1990 a month and a half after the murders, it

mentions that Major Buckland, officer of the United States

Army, and advisor to the armed forces of El Salvador,

reported to his superior Lieutenant Colonel William

Hunter, a conversation he had some days previously with

one of the Colonels of the Armed Forces. During that

conversation, Buitrago had told him what he had learned,

that Colonel Lopez and Venavides had arranged the murders,

and that the unit from that battalion had carried them

out. He also said Venavides has asked Colonel Rivas

Najarro for help. In other words, it seems to me that the

government of the United States was also aware of what was

happening.

And I would like to turn to page 111 at

this point, “The Massacre of Peasants by the Armed

Forces.” And at the bottom paragraph, on the 10th of

December 1981, in the village of Mozote, in the Department

of Morazan units of the Battalion detained without

resistance, all the men, women and children, who were in

the place. The following day, the 11th of December, after

spending the night locked in their homes, they were

deliberately and systematically executed in groups. First

the men were tortured and executed. then the women were

executed and lastly the children in the place where they

had been locked up. The number of victims identified was

over 200. The figure is higher if other unidentified

victims are taken into account. It was estimated at that


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time that Mr. Figueroa has information by living there at

that time, they estimated that there were a thousand, who

were executed at that time.

I’m trying to point out that this kind of

atrocities that was taken place by the government -- as

were reported on April 14th, in the hearing, that the FMLN

also did some mayors, but their goal was a total different

tactic. They were asking mayors to resign, and what they

did totally was reported -- was blowing up bridges and

roads, not to attack the people but also to do something

to the economy to bring the government to the point of

having a discussion so that they could bring peace to the

land. It was also in 1989, there were peace negotiations,

as we find also in the Truth Report, but were broken off

by the FMLN, because while they were having peace

negotiations the government forces bombed some of the

groups and organizations supporting the FMLN, bombed their

offices, and therefore they withdrew saying that this

seemed to be rather futile.

I would like to point out, in some of my

closing remarks that, as was mentioned by the Minister,

that Mr. Figueroa was not engaged in combat at the time.

It was used the term “terrorist”, but this was a civil war

that was going on within the country, so it was two

factions that were fighting. I might want to compare that

to the Canadian Forces in Afghanistan. They are fighting.

There was a definition given for terrorist that was the


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harm of people, harm done to people. When there is a war

there is harm done to people. Our Canadian forces are

doing some harm to some people as a result of fighting in

Afghanistan. I support my troops in Afghanistan, I trust

that that does not make me a terrorist, because I support

them.

I do have an article here that I cut out of

a paper from The Globe and Mail where one of our forces

just asked the other people to turn their heads while

somebody that they had taken into custody -- and he shot

him. That you might say is a terrorist act, and yet he is

of my government. I support that. So this things

happened also at that time. I don’t think that you can

classify them as terrorists, but as the thing that the

Canadian government is trying to do there is to bring

peace to Afghanistan. I believe that the FMLN -- without

the FMLN, there would never had been peace brought to El

Salvador. There would have still been death squads,

there would have still been the atrocities which the

homilies referred to going on an on and on, to the point

that finally even the priests could not keep quiet

anymore. They had to speak out against what they were

seeing happening.

Being that, it was pointed out, he was not

engaged in combat. Mr. Figueroa was at University at

this time. His role there was a representative of the

students on the faculty council. He was chosen as the


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valedictorian in for his grad, in July 24th of 1992. The

peace accord had already been signed in January of 1992

and so he did graduate and he has a copy of his

graduation. And therefore he also -- in order, believing,

to see what had seen personally happening, what the

government was doing to the people, he would recruit at

the university members to support specially the FMLN in

their -- when you go down the street and demonstrate, in

their demonstrations. Had that not happened, to have a

force, to bring more people into the FMLN, the peace

accord would never had taken place. When it did take

place there were nine countries there in Mexico to give

approval, including the United Nations Secretary. And

they believed and they stated that this was one of the

best peace accords and has been held up to this time.

I did want to mention that in, on the law

83.05 --

MR. FIGUEROA: **** 56:15 ***

Just a little bit over on this, just

before he goes onto the law stuff. We included the

sermons from Monsignor Romero – that’s how we called him,

Archbishop Romero – because these homilies basically

represent for the Salvadoran people what the Commission on

Truth represent after the peace accord in the decade of

the ‘80s. The mandate of the Commission on Truth on El

Salvador was to report all the atrocities that were

committed during the war during that decade. And the


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homilies of Monsignor Romero represent basically what was

happening before on El Salvador. And those were even

bigger atrocities that caused the people to organize, to

fight against the repression. And with this, you know,

they are right now trying to point out FMLN as a terrorist

organization, when indeed what it was, was a group that

started to work against a tyranny. And that is stated in

the universal declaration of human rights. When all the

means have been gone, the last resort of the people is

rebellion. And that is something that we have to point

out.

The other thing is that the Commission on

Truth when it came out in 1993, it hasn’t been refuted

neither by the government of El Salvador, nor the FMLN,

nor even the government of the United States have refuted

what is stated in this Commission. So that gives the

Commission on Truth the validity of something that you can

use as evidence of what was going on in El Salvador.

I want to point out something in Volume 3

of the evidence presented by the Minister, and this is the

report on the -- the report of the United Nations

representative of human rights, Pastor Ridruejos, from

1987 through 1992. On page 4, on the –1,2,3 – on the

fourth paragraph, if you can see there, it says: “Since

government….” On the bottom of that paragraph it says:

“Since the government of El Salvador continues

to have legal reservations concerning the


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mandate of special representative, the latest

visit was authorized not in that capacity, but

in the capacity of a Spanish citizen.”

You know, during all this time, all of this atrocities

that were going on, obviously the Salvadoran government

didn’t want any witness. That’s why they denied this

special representative to go there in that capacity.

On the next page, on page 5, you will see

on the – 1, 2, 3 – also on the fourth paragraph, the

special representative met with members of the politic

diplomatic commission of the FMLN-FDR. That was in Spain.

The question would be: Which terrorist organization has a

diplomatic representation? That’s a question that we would

have to ask the Minister in this case.

The other thing that we want to emphasize

in this is that this corresponds with the time the

declaration of France and Mexico with respect of El

Salvador. And the other thing about this commission, the

report on the -- given on this Exhibit, this was done

during the context of the war and they represent -- Pastor

Ridruejos, the special representative, he just met with

the representatives of the government basically. All this

information was given by them, which make their

information bias. And in that respect, if we want to

refer, the Commission on Truth would represent the truth

of what was going on in El Salvador, because it was given

freely by the people of El Salvador.


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REV. KELLER:

Okay. I do want to point out, that the

section of the Criminal Code, 83.05. The Criminal Code

establishes what are a list of entities, which are

reasonable grounds that they are terrorist organizations.

And the FMLN is not listed, and therefore when Officer

Hindson gives his opinion, and he said, this is his

opinion, then I believe that’s all it is, is just an

opinion.

And also if we could take Volume C-2 --

that was presented on the 14th -- it’s evidence filed by

the Minister, tab 3, page 22, about the middle there, it

says “current goals”. And it says:

“The FMLN was dealt a death blow when the U.S.

decided to support the Salvadoran government.

Still politically inspired violence, no longer

in….”

PRESIDING MEMBER:

What page?

REV. KELLER:

Pardon?

PRESIDING MEMBER:

Tab 2, page ?

REV. KELLER:

Page 22, tab 3. C-2

PRESIDING MEMBER:

Right.


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REV. KELLER:

Yeah.

“…still politically inspired violence, no

longer in the form of direct engagement,

continued until 1989. On December 31, 1991,

the FMLN reached a peace settlement with the

Salvadoran government that allowed the FMLN to

participate in political affairs. In exchange,

the government cracked down on the notorious

right wing death squads that were responsible

for the majority of the human rights violations

that occurred during El Salvador’s civil war.”

It did not call this a guerrilla war but a civil war.

“Today the FMLN is one of the two main

political parties in El Salvador, and can no

longer be considered a terrorist organization.”

So they referred to it at this time as not a terrorist

organization, and in fact, the government of today the

leader is --their party is the FMLN, which the government

of Canada obviously recognizes and has ambassadors here at

this time.

And therefore, I believe that in my opinion

with Mr. Figueroa involved in the FMLN, his goal was to

help to bring peace. And the result in 1992 helped to

bring peace to El Salvador, for the repression of the

people of El Salvador. And therefore, consider him to be

a very valuable citizen and an advantage to our country.


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MR. FIGUEROA:

Your Honour, referring to P-2. This was a

research we made with respect of the resolutions of the

United Nations. It is a compilation of basically all the

United Nations Security Councils basically since the

September 11 events. Resolution 1373, in this resolution,

the United Nations Security Council asked the members of

the United Nations to incorporate in their law elements to

in order to combat terrorism. And that research, we went

into this research, due to the fact in section 83.01 of

the Criminal Code, not only establishes a definition of

terrorism, it also establishes mechanisms in order to list

and delist members of terrorist organizations. And in

that respect, that’s why we went into all of this research

about where this is coming from.

If you see in P-2, in tab 1, that is a

discussion that was made in the House of Commons about the

Resolution 1373. In this resolution, the House of Commons

establishes, based on resolution 1373, three different

mechanisms in order to make this list of entities which is

mentioned in the Criminal Code.

The first mechanism was very, very specific

and it was referred to the Al-Qaeda, Taliban, Osama Bin

Laden resolution. And that’s how they basically called

it: The United Nations Al-Qaeda and Taliban Regulations,

UNAQTR.

The second mechanism that was established


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on this Commission it was the United Nations regulation

implementing the United Nations Resolutions on the

Suppression of Terrorism. And all of this has a lot to

do. Officer Hindson, and the Minister representative

tried to fit FMLN into a definition of terrorism. A

definition to which not only FMLN would have fit, you

could fit the United States government for financing

terrorism during the decade of the ‘80s. You could fit

many other organizations as the government of El Salvador

then.

Right now, we can see that Canada has

relationships with FMLN through their government. They

are not being seen as a terrorist organization. Therefore

to be pointing out individuals that had some relationship

with the FMLN as a terrorist, that’s an absurdity. If we

go, try to universalize the law itself, pretty soon, I

guess that prisons in Canada will be filled with a lot of

politicians that are supporting the government of El

Salvador, or any thing that fit into the definition that

has been trying to be put here through the opinion of the

Minister.

So, that’s why we present all of this as

evidence on how the things have been presented here in the

Court.

REV. KELLER:

And I think that just to leave it at that.

The key for me, at least, was when 85


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percent of the atrocities were done by the government and

only 5 by the – which are too many in my opinion – by the

FMLN, but it did bring peace.

PRESIDING MEMBER:

Okay. Did you have more to talk about?

MR. FIGUEROA:

We have more evidence, but I think that we

have --

REV. KELLER:

I don’t want to duplicate over and over

some of the atrocities that happened. I think 85 percent

says enough, rather than me going through all those. I

think that would be redundant.

PRESIDING MEMBER:

Okay. Well, in her submissions as I

recall, Ms Teran, zeroed in one particular type of rather

bad activity, and that’s I believe -- as I recall was the

attacking of mayors by the FMLN. Correct?

MS. TERAN:

That was one of them, yes.

PRESIDING MEMBER:

I recall there were quite a number of

allegations of that particular activity taking place.

MS. TERAN:

Yes.

PRESIDING MEMBER:

Now, that would -- that sounds like a


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rather serious type of activity. I guess I should ask to

you. Is your view that those types of attacks were

contained within the 5 percent allegation that the

Commission came up with -- or do you have any comment what

that 5 percent entailed?

REV. KELLER:

I don’t have any --

PRESIDING MEMBER:

What type of activity?

REV. KELLER:

Well, except what we have in Truth Report,

but being that this was a United Nations’ report and the

experts that they had gathered to find this report and the

forensic evidence that they had, yes, the mayors, they

were not -- as you recall, I believe was 100 and some

mayors that resigned, and therefore were fine. They

didn’t -- but there were a few that lost their lives. The

then as I say the 5 percent is too much in my opinion, but

it was 5 percent, but it was a civil war and it did bring

-- and the purpose of the FMLN was to bring peace to the

country, which they accomplished to this day. And many --

without the FMLN, many, many more lives would have -- and

atrocities would have occurred.

MR. FIGUEROA:

Well, at the beginning of today we were

trying to convey some questions that we were presenting

and in that respect, you know, like when we go through all


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of these aspects of the law, section 83.05, is the

Minister of Public Safety responsible for maintaining that

list? We included in the evidence the list of entities

and that will be on -- the list of entities is in one of

these. Okay. On tab 23.

PRESIDING MEMBER:

Which Exhibit?

MR. FIGUEROA:

On P-2, on tab 23. We include the list of

entities as it is published in the Gazette, with the

latest modification that was introduced on March this

year. And if you go through that list of entities you

will see that FMLN is not included on this list. And

couldn’t had been included. FMLN has been a legal

political party in El Salvador, since 1992 and there are

over two million Salvadorans that they don’t consider as a

terrorist organization. And when we are presenting this,

basically by law, they’re basically cutting off two

million people that are not eligible to get into Canada.

So just I would like to go a little bit over.

And the reason why we presented all of

this evidence, and we also presented to you the report of

-- a copy of peace agreement that was signed in

Chapultepec, Mexico, between the FMLN and the government

and where they established this Truth Commission. And

they did a lot of changes in El Salvador. And right now,

they are -- as the pastor said, this peace accord is a


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model for resolving a conflict in a country. And the

United Nations, they tend to -- the Security Council, they

will make resolutions referring to terrorist activities.

I have -- I went through all the resolutions that the

Security Council made since 1946, since the United Nations

was created and on those resolutions there are only about

three resolutions they do concerning El Salvador and that

was during the time that the negotiation was done, and in

neither of those they refer to FMLN as a terrorist

organization. So in the view of the United Nations, the

FMLN is not a terrorist organization.

PRESIDING MEMBER:

So, just briefly, what age were you when

the peace accord came?

MR. FIGUEROA:

I was born in 1966.

PRESIDING MEMBER:

And the peace accord is when?

MR. FIGUEROA:

In 1992.

REV. KELLER:

So, you were about 14, if ’66 --

MR. FIGUEROA:

When the war started.

REV KELLER:

No, when he was assassinated.

MR. FIGUEROA:


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When Monsignor was assassinated.

REV. KELLER:

If my math is correct.

PRESIDING MEMBER:

So, you were 18 when Monsignor was

assassinated?

MR. FIGUEROA:

Fourteen.

PRESIDING MEMBER:

Fourteen.

REV. KELLER:

But it was between 1981 when 75 percent of

the --

(PHONE RINGING)

Oh my goodness, I thought I turned that

thing off, sorry. Sorry.

PRESIDING MEMBER:

Okay. Well --

REV. KELLER:

That’s when 75 percent of the atrocities

took place when he would had been between 14 and 18.

MR. FIGUEROA:

If I am not wrong, in part your mandate

for this hearing in the IRPA in article 44. There’s a

part in there. Let me see if I can find it.

PRESIDING MEMBER:

Section 44 of the Act?


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MR. FIGUEROA:

Yeah. Section 44 just to -- see, I don’t

know if that -- I guess that we have already talked about

that, but your mandate was to determine if FMLN was a

terrorist organization, is that correct?

PRESIDING MEMBER:

Right. If it was a terrorist organization

and if you were a member of the organization.

MR. FIGUEROA:

Yeah, because what we were -- where I’m

trying to go in this is because of the proceedings. I

have gone investigated a lot about how the case have been

handled and I noticed a lot of mistakes -- on this, how

they have been and just to point out that if you want to

hear about that or if it is in your mandate to determine

that, because --

PRESIDING MEMBER:

Well, I play by -- I noted that last time

-- I’m not here to sit and review what the Minister’s

delegate might have done, as it’s the Minister’s

delegate’s job to put together the information and if they

think it’s warranted then they make a report. And then

once I have the report, it goes to a delegate to decide to

whether or not force you to come here. So it’s not my

job, or my jurisdiction to see whether they did that is

correctly or incorrectly. That’s not part of my

jurisdiction. Once I’m presented with the referral and


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the report, then I have to consider is it founded or not.

REV. KELLER:

It seems to me that the option at the

university -- well, I didn’t read that section. I’ll

share that with you. But they came to the university and

the professors -- they challenged the professors that if

they didn’t change their ways, they would also meet the

same situation as the others. Out of the 15, nine of them

left the country for their own security. They were the

professors at the university of which he was a part.

It seems to me that as I read all of these

information, if you wanted an option for change, the only

option was the FMLN. The status quo was the death squads,

and what the armed forces were doing. And that was not an

option. And you couldn’t be neutral. You had to be one

way or the other. And that’s why I shared the homilies of

the situation of the country, that the country was in.

It’s very hard for me to basically to understand this in

Canada. That’s -- I’ve been all over the world, but I

cannot -- I’ve been in Africa a lot. I cannot comprehend

this kind of -- living in this kind of situation. And

being neutral. You couldn’t be.

MR. FIGUEROA:

Pastor. He mentioned about the last

paragraph of homily on 23 of March, that was the day

before Monsignor or Archbishop Romero was killed. He

addressed to the members of the army, and in that address,


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if you want to get to that homily, that’s of March 23,

page 17. That’s the last page. That was the address that

Archbishop Romero did to the Army. And it says.

“I would like to make a special appeal to the

men in the army and in particular to the bases

of the National Guard, police barracks.”

The National Guard was basically the main repressive

instrument that the government used against the

population, and in all of these homilies they refer -- he

refers to all these atrocities that had been happening in

there, and Monsignor Romero he was a very conservative

priest at one point. When he saw all of these atrocities,

he started to speak up against these injustices. And he

did it broadly, he spoke for the people, he became the

voice of the voiceless in El Salvador. And on this

homily, I just want to share the last part of this. It

says -- he is calling that:

“Soldiers do not disobey the law of God, which

says, ‘Do not kill’.”

And this was -- I just leave you to read that part.

REV. KELLER:

And at the end here it says finally:

“I beseach you. I order you in the name of

God, stop the repression.”

He was strongly of incredible repression that was going on

in the country.

MR. FIGUEROA:


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As a young -- when I was little I just

remember, I was watching TV. That was the day before

Archbishop Romero was killed. And I just could see how

many people were killed at that time. I was just little.

Those images they sound on my heart, I tell you. And the

messages -- as a student, I studied a lot Monsignor

Romero’s life. And I could see how he changed. And

right now, I make a reflection on myself, and if I was in

El Salvador, basically if the conditions were on the same

situation, more likely I would be supporting FMLN again

through the organization of the students. I could see

members of other organizations in El Salvador that were

killed. I remember members of FENASTRAS, we met with them

when we organized the marches, in order to try to pressure

into the government to go and make peace. And those

images are still here in my mind. So, if you want, you

can say, whatever you are -- it is in your hands to take

this. We presented the Commission on Truth the whole

report because in order to know the truth it is necessary

to see whole situation, not just pieces here and pieces

there in order to try to fit something into a definition.

And if you want to proceed and look for justice, it’s my

belief that the whole truth has to be considered.

PRESIDING MEMBER:

Okay. Well, you’ve presented a number of

books of documents. You made reference to certain parts

of them. Does that mean that what you told me orally is


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the crux of your argument, that that is what I need to

relay on? Because I there’s a lot of reading and unless

you can pinpoint me to things in all of this

documentation, I don’t know that I would be able to read

it, individually go through picking out points.

MR. FIGUEROA:

Okay. I would say the Truth Commission,

the homilies of Monsignor Romero and if you can go on line

and research on that, it will be up to you but --

PRESIDING MEMBER:

Well, I’m not in a position to go on line

and start looking at documents. It’s a little bit too

nebulous for me. I don’t know what I will be looking at,

what was written by, or what has been amended by, and

when.

MR. FIGUEROA:

Exactly,

PRESIDING MEMBER:

No, I can’t do that.

REV. KELLER:

I feel that what we are giving you from

the Truth Report especially, as well as, you know, what

Mexico and France did in 1981. To do more is just to

repeat.-

PRESIDING MEMBER:

Okay.

REV. KELLER:


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And I think that you have sufficient

evidence to make that kind of decision and to bore you

with repetition as -- I know repetition aids learning,

they tell me in school but I don’t think it matters

necessarily here.

PRESIDING MEMBER:

Well, repetition isn’t very kindly looked

on here. I’ll put it that way. So I appreciate your

candor.

So Ms. Teran, I would expect you probably

have a reply of some sort.

MS. TERAN:

Just very brief.

PRESIDING MEMBER:

Well, perhaps we’ll have a break. Shall we

take a break until 5 to 3:00?

MS. TERAN:

Yes, although, you know, I don’t think

that my reply is going to take more than 10 minutes.

PRESIDING MEMBER:

Well, perhaps we take a 5 minutes break?

MS. TERAN:

Sure.

REV. KELLER:

Yes, let’s take a 5 minute break. Thank

you.

PRESIDING MEMBER:


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Okay. Thank you.

(PROCEEDINGS ADJOURNED)

(PROCEEDINGS RESUMED PURSUANT TO ADJOURNMENT)

PRESIDING MEMBER:

We are back on the record with the same

parties present.

Now, before we get to Ms. Teran’s reply,

I have a question for you Mr. Figueroa. The Truth

Commission’s report gave some percentages of where all of

these bad atrocities were arising from. It suggested 5

percent came from the group that we are talking about

here. I guess my question is sort of a general one. Do

you accept that the group did commit atrocities? And what

was your knowledge of the atrocities?

MR. FIGUEROA:

What I know was what was going on in El

Salvador, and in my view I never saw FMLN as a terrorist

organization. And that’s what I saw in El Salvador.

That’s was the general violence that was going on. So I

cannot say this thing was happening with FMLN or the

government. Like right now --

PRESIDING MEMBER:

Well, you saw -- you obviously saw a lot of

violence

MR. FIGUEROA:

A lot of violence, and all the violence I

saw was reflected on the mass organizations, on the


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people, and that’s how I see it. And my work at the

university was to talk about this, basically to try to

open the people’s mind on what was going on in El

Salvador.

PRESIDING MEMBER:

Okay. To what degree would you have an

understanding or acceptance of that 5 percent?

MR. FIGUEROA:

If I had an acceptance? War is not good

anywhere. That’s my general opinion. And my work as a

student union at the university was to make something in

order to go and make changes in El Salvador. And so, I

cannot say that I did not -- that I didn’t see people

being killed, yes I saw people being killed on the streets

and --

PRESIDING MEMBER:

Well, did you accept at that time that the

FMLN did some killing?

MR. FIGUEROA:

In the context of the war, I would say

yes. It was an armed conflict.

PRESIDING MEMBER:

Yeah. Okay. Well, you said that you

viewed it as an armed conflict, it was an armed conflict,

everybody is fighting and there is deplorable actions

taken by all sides. Can you say whether or not you

condoned the violent actions of the FMLN?


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MR. FIGUEROA:

I condone everybody’s actions.

PRESIDING MEMBER:

Well, I’m not trying --

MR. FIGUEROA:

I am not trying to justify FMLN actions as

that. But if you want to see my point of view on that

thing, is that violence -- and that’s why I was always

working at that time the university and exposing myself to

the death squads basically. And thus as everybody else

that was organized in different organizations.

PRESIDING MEMBER:

Okay. Well, you were trying to get people

involved with the FMLN so there would be a change in

government. While you were doing that, did you promote

violence?

MR. FIGUEROA:

No.

PRESIDING MEMBER:

Okay.

MR. FIGUEROA:

I don’t believe I did.

PRESIDING MEMBER:

So how would you characterize promoting

what you did in trying to affect this change?

MR. FIGUEROA:

In order to open the people’s mind into


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their own reality. That’s basically -- I was a student at

the university. I was a representative of the students

at the University council and during that time that I was

there, the university was trying to make changes into the

curricula, incorporating into the studies elements of the

reality into the subjects, to talk with the students about

the reality. That was part of the objective of

university.

And if you go and research about this there

was this university project that was trying to promote the

values of students, that they graduated from the

university and they wouldn’t go to perform their careers

or whatever in order to go exploit people. But in order

to try to promote in them to go and work with the

community. That was basically what was being done during

the university.

PRESIDING MEMBER:

Okay. So, Ms. Teran, your reply.

REPLY BY MS. TERAN:

MS. TERAN:

Thank you. Just as I mentioned earlier,

very brief.

Mr. Figueroa had mentioned the

documentation that’s presented by the Minister in Volume

3, which I think is marked as C-3, if I am not mistaken.

I didn’t bring it with me, but -- I only brought the first

two volumes. Which is the -- essentially all the tabs


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that are there which are 8 tabs are all the reports that

were presented to the UN General Assembly report on -- of

the Economic and Social Council, situation of human rights

in El Salvador. Now, Mr. Figueroa mentioned that the

information that was gathered by this special

representative came solely from the representatives of the

States, the Salvadoran government and that’s being bias.

However, if you go through each of the reports, in it the

special representative cites the various sources that he

consulted prior to writing the report. So I would be in a

great disagreement with Mr. Figueroa, when he says that it

was solely coming from the government when, in fact, it

was coming from a variety of sources, not only from the

government, but as well from the FMLN, and other

independent sources. And that’s for all of the reports.

Now, what is interesting and I didn’t go

into the last time because the fact that it was

repetitive, what was in Exhibit C-2 and that was

essentially all that documentation that’s presented on

those tabs, is essentially or mirrors the same information

that’s found in C-2. And again, the documentation that’s

found in C-2 is, again, not only is the Truth Commission

-- a portion of atrocities which were committed by the

FMLN included in C-2, but also a variety of other

sources.

Now, the other thing that I wanted to

perhaps bring to your attention, the book of authorities


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that I provided to you which I believe was marked in as

Exhibit C-4, in the last -- again, which I did not bring

with me. In the last tabs of that booklet you will find,

although is not binding on you, you will find the

decisions by the Immigration Division Tribunals, not just

from this region, but also from the eastern region of

Canada on specific decisions dealing with the 34(1)(f) as

members of terrorists organizations, and that being the

FMLN. All of those decisions, if you go over them --

specially there’s one there which was done by member Shaw-

Dyke before she retired, and I was the Minister’s

representative on that. The same material that’s included

in that decision, I’ve provided in the various Volumes

that the Minister has provided.

Now, as I mentioned before, it is not

binding on you. However, she did find that the

information that was provided by the Minister, which again

the information that is included in the volumes that the

Minister provided in this case, was found to be credible

and trust worthy. There is other --

PRESIDING MEMBER:

Just -- I see Mr. Figueroa is following

along. I believe that’s the decision found at page 137 of

Exhibit C-4. REV. KELLER:

137?

PRESIDING MEMBER:

Yes, that’s the decision by Member Shaw-


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Dyke on Mr. Montoya (inaudible).

MS. TERAN:

I apologize for not referring to the

specific pages, but as I mentioned I don’t have -- I

didn’t bring that booklet with me.

Now, aside from that decision, there’s also

other decisions not just by the Immigration Division, but

also from the IAD, which I come to the same conclusion as

member Shaw-Dyke did in that decision that you just cited,

basically concluding that the FMLN, based on the

information that the Minister provided, had committed

terrorist acts during the armed conflict that took place

in El Salvador from 1980 to 1992.

In Mr. Figueroa’s own evidence as well on

P-4, although it is being looked on a different context,

there is a decision from -- and I believe it is on tab 3.

Now, this decision is not from Immigration Division, but

is from the Refugee Protection Division, excluding two

individuals, a couple that was married for having been

members of the FMLN, it concludes that the FMLN, on

paragraph 53 of that decision, to be a limited brutal

purpose organization.

And that’s the end of my reply.

PRESIDING MEMBER:

Perhaps, I’ll address a few specific things

that Mr. Figueroa and his counsel brought up and I’ll see

if you have any comment on them.


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MS. TERAN:

Sure.

PRESIDING MEMBER:

Firstly, they noted that the FMLN isn’t on

the list of entities. If it was a terrorist organization

it would be there. So what’s your comment on that?

MS. TERAN:

Well, there’s many organizations that have

been brought to this Division where they’re not on the

list of entities and the reason for that is -- it’s a

political process, it takes years, and also the fact that

the FMLN today is considered a political party. It’s no

longer -- it is no longer considered an organization that

is engaging in armed struggle to overthrow the government

of El Salvador.

MR. FIGUEROA:

Your Honour--

PRESIDING MEMBER:

Well, I mean, I’m not -- I don’t know that

the second comment that you make really will carry a lot

of weight. One corresponding to groups such as the MQM of

Pakistan--

MS. TERAN:

Correct.

PRESIDING MEMBER:

--which is the third largest political

party, and members of which are still being brought before


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this division.

MS. TERAN:

Yes. I --

PRESIDING MEMBER:

And it’s not on the list.

MS. TERAN:

Correct, and I mean, another example, it

was only a few years ago that the LTTE was listed in that

category, but prior to that the Minister of Immigration

had been bringing -- or has been brought reports that --

allegations to this Division as well as the RPD, alleging

that the LTTE was engaged in terrorist acts, and it was in

fact a terrorist organization. And it’s only been a few

years, now that the LTTE has been listed in the Solicitor

General’s list.

I can speculate and provide you with my own

personal views as to why.

PRESIDING MEMBER:

No, I don’t --

MS. TERAN:

But I am not going to go that route.

PRESIDING MEMBER:

No, I don’t -- and I wouldn’t listen to it

anyways, I’m afraid.

MS. TERAN:

Yes. So.

PRESIDING MEMBER:


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They mention that -- Mr. Figueroa mentioned

that there’s, he believed, three United Nations

resolutions respecting El Salvador and none of those

resolutions refer to the FMLN being in anyway as terrorist

group. Anything you want to say about that?

MS. TERAN:

Well --

PRESIDING MEMBER:

I guess that’s it’s perhaps so broad

that --

MS. TERAN:

I can’t really comment on that.

PRESIDING MEMBER:

Yeah. I mean, we don’t know what those

resolutions specifically were dealing with so I consider

it might be rather difficult you to comment on that.

MS. TERAN:

I mean. The same thing could be said with

this country listing, say, the LTTE as a terrorist

organization and then looking at France or England and

say, “Well it’s not listed in there.” Everybody has their

own process and definition of what terrorism is.

PRESIDING MEMBER:

Now, one of the main arguments made by the

other side was that there was a horrendous repression

going on in El Salvador around this time. And basically,

the only route was to somehow force a change. If the


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change had not been forced then the terrible repression

and death squads would’ve continued. So I guess the

others suggestion is that they had to go this route. Any

particular comment on that?

MS. TERAN:

I think that that’s for -- perhaps

section 34(2), the Minister may deal with that issue.

Regardless --

PRESIDING MEMBER:

So, section 34(2) deals with the Minister’s

exemption?

MS. TERAN:

Regardless, of the conditions, yes, you can

take steps to rebel and cause a change. However, I would

submit that the FMLN went beyond that. It’s initial cause

got lost in the fighting. And there was -- and I’m not

going to -- I mean, the Minister is not denying that there

wasn’t [sic] any atrocities committed by the government of

El Salvador. There was. In fact, we’ve taken cases

before this tribunal and the RPD as well on members of the

State who were members at that time. So, I’m not denying

the fact that atrocities were not [sic] being committed.

It doesn’t make it -- it doesn’t make it any -- it doesn’t

make it acceptable for the FMLN or the government to take

the actions that they did.

PRESIDING MEMBER:

I guess that the final comment will be with


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respect to the other side’s comment that, well, there’s

perhaps 2 million members of the FMLN now in El Salvador.

Bringing this type of inadmissibility hearing would mean

that those 2 million people would be inadmissible to

Canada.

MS. TERAN:

Well, I don’t know because those 2 million

people are not here. So, it’s a case by case -- if in

fact every member of the FMLN was inadmissible to Canada

and the government believed that, then perhaps they’d go

the route and list the FMLN as a terrorist organization.

I can’t -- I can’t tell you about those 2 other million

people.

PRESIDING MEMBER:

And this maybe a question which is

completely unrelated to your field of knowledge. Do you

have any knowledge of Ministerial exemptions for people

who formerly belonged to the FMLN?

MS. TERAN:

With respect to being given the exemption?

PRESIDING MEMBER:

Correct.

MS. TERAN:

I have not -- I have not come -- none of

those have come across --I haven’t come across any.


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PRESIDING MEMBER:

Now, would those be the types of cases that

you would expect to come across if they came up or is it

simply another area of the Department that really you have

no contact with?

MS. TERAN:

The only reason why I would come across

with such a case or decision is if it came back. Because

the way that the process works is everything is done in

Ottawa. There’s a special section within CBSA that deals

with the Minister’s exemptions. And I can’t tell you how

long they last. I know there are cases where it’s been

five years, six years, and we still don’t have a decision.

So when we do come across one, then at that point the

individual is called in and there’s a procedure that goes

in place where we go into our computer system and they’re

no longer inadmissible. So as far as I am concerned, the

number of years that I have doing this which has being

eight years as a hearing officer, I have not come across

an exemption based on membership on the FMLN.

PRESIDING MEMBER:

Well, conversely, would you have come

across other exemptions that sort of come across your desk

and you realize, “Oh, here’s an exemption”?

MS. TERAN:

Yes. Yes, there’s been one or two.

PRESIDING MEMBER:


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Not a whole lot.

MS. TERAN:

No, not a whole lot. But then again, you

don’t see many exemptions. You don’t see many

applications, or do again, because of the time it takes.

PRESIDING MEMBER:

Right. And I don’t know whether you would

have any comment on what the state of removal arrangements

would be during the time that somebody who has had an

exemption application underway?

MS. TERAN:

It depends on secondary factors. It

depends -- for example, it depends whether or not there’s

an application still standing for permanent residency on

an H&C application. Those based on the manuals, which are

open to the public are on the website. There is a

recommendation by Ottawa, that says that we are unlikely

to remove. So pending a Ministerial application decision.

PRESIDING MEMBER:

Okay.

MS. TERAN:

So, normally, you take a look at -- you

base it on a case by case, and if the case warrants a

delay of removal or a stay of removal then that’s given.

PRESIDING MEMBER:

Okay. So these are rather corollary

questions, obviously, that I’m asking at this point.


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Okay. I have --

MS. TERAN:

Sorry, just to elaborate on that. I did

-- I know that Mr. Figueroa has an outstanding H&C

application and because – I don’t know if he will or if he

won’t, that’s his choice – but based on my conversations

with CIC it -- and based on the guidance that was given to

us by the manuals. He may not -- there may be a stay of

removal. There is a stay of removal that CIC provides

pending the decision by the --

PRESIDING MEMBER:

That other application. Okay.

MS. TERAN:

Yes, so. I think that more directly

answers your question.

PRESIDING MEMBER:

Right. Well, it’s another aspect to my

question. Another answer -- another aspect to the answer

to my question.

So, I’ve been provided with a lot of

evidence, a lot of submissions. Obviously, I will need to

review all of this before I render my decision. However,

is my intention to render an expeditious oral decision.

We’ll take a short break now to figure out what date that

might be.

(END OF RECORDED PROCEEDINGS)

I HEREBY CERTIFY THAT THE FORGOING

is a true and accurate transcript of


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the recording provided to me, to the

best of my skill and ability.

__________________________________

D.A. BEMISTER, TRANSCRIBER

Jose Luis Figueroa/ Admissibility Hearing April 29, 2010/Held at Vancouver, British Columbia

Documents

Transcript of Jose Luis Figueroa/ Admissibility Hearing April 29, 2010/Held at Vancouver, British Columbia