28 crime of false accusation, in order to protect the reputation of a public official allegedly accused of illegal acts are therefore out of proportion with the 'interest justifying' such laws, as required under Article 13(2) of the Convention.” It also results out of proportion “[…] when the criminal punishment imposed does not imply an imprisonment risk but rather the payment of a fine calculated on a daily basis.” Finally, it requested that the violation of the obligation to bring the Panamanian legislation into conformity with the international standards be declared insofar as “the Panamanian legislation entails the threat of imprisonment or fine for those who insult or offend public officials or express critical opinions given by third parties about public officials or about private individuals who voluntarily take part in matters of public interest.” 91. The representatives, among other arguments, advanced that: a) the exercise of freedom of expression is not exclusively reserved to journalists and all individuals must be fully guaranteed the possibility of communicating and receiving information, ideas and opinions. Likewise, they considered that “[t]he protection granted under Article 13 of the American Convention covers not only assessments, but also statements regarding matters of public interest related to the exercise of democratic control [,including] any statements that may be considered offensive”; b) “the legislation of Panamá applied in the case [of Mr. Tristán Donoso] does not allow for open and transparent debate regarding public matters and spawns fear to disseminate information, thus causing a serious detriment to the operation of the democratic system, particularly when involving matters of public interest”; such legislation releases public officials from the duty to submit summary evidence when pressing criminal charges against third parties for crimes against honor and provides for the verification of the truth -exceptio veritatis- as a means to exempt from punishment those who commit a crime against honor, for which reason such legislation does not comply with freedom of expression international standards; c) “the protection of honor of those under the jurisdiction of the State of Panamá is a legitimate purpose”, however, since there are other means that are less restrictive, such as those indicated by the Commission, “the statutory definition of the crimes of slander, libel and defamation become a necessary means to achieve the legitimate purpose pursued”; and d) the rules on civil compensations do not clearly establish “a distinction regarding the type of criticism involved [regarding public or private individuals], do not […] establish neither an actual malice standard nor a the purpose of compensation and do not include measures to guarantee that the penalty be commensurate.” They concluded that the criminal conviction of Mr. Tristán Donoso, as well as the civil compensation payment imposed upon him – the amount of which is to be determined ─ violated his right to freedom of expression. 92. Finally the State held that: a) the instant one “is a clear case of subsequent liability ─ as expressly set forth in Article 13(2)(a) of the American Convention ─ , resulting from an illegitimate attack by Tristán Donoso against the rights and reputation of others”; b) the victim could, at all times, exercise his right to freedom of expression and “the accusation publicly made by Mr. [Tristán] Donoso […] could not be understood as ‘criticism’ or ‘public debate’ regarding the acts of a public official.” Considering an act of false accusation as “news of high public interest” is equivalent to legitimating any illegal act performed upon exercising freedom of expression, provided such act may draw the attention of the public; c) the sections of the Penal Code “constitute a protection granted by the State to the right to honor and reputation against illegal acts, enshrined in Article 11 of the Convention and Article 17 of the Constitución Política de la República de Panamá [Political Constitution of the Republic of Panamá], which protection is consistent with the