39 telephone, as other authorities were accusing him of doing, especially considering that no answer was given to the questions he posed in the year 1996.114 128. Likewise, the First Instance Court specified that: […] we must recall that it was not until an inquiry was started in March 1999 and a Court decision was rendered that it became possible to verify that Licentiate José Antonio Sossa, Procurador 115 General de la Nación [National Attorney General], had no participation in the instant events. 129. Lastly, even though the days’ fine does not seem excessive as a punishment, the criminal conviction imposed as a form of the subsequent liability established in the instant case is not necessary. Additionally, the facts the Tribunal is examining show that the fear of a civil penalty, considering the claim by the former Attorney General for a very steep civil reparation, may be, in any case, equally or more intimidating and inhibiting for the exercise of freedom of expression than a criminal punishment, since it has the potential to attain the personal and family life of an individual who accuses a public official, with the evident and very negative result of self-censorship both in the affected party and in other potential critics of the actions taken by a public official. 130. Based on the above, the Court finds that the criminal punishment imposed upon Mr. Tristán Donoso was evidently unnecessary, considering the alleged violation of the right to honor in the instant case, for which reason it results in a violation of the right to freedom of thought and of expression enshrined in Article 13 of the American Convention, as related to Article 1(1) of such treaty, to the detriment of Mr. Tristán Donoso. 131. On the other hand, it has not been shown in the instant case that the abovementioned criminal punishment was the outcome of alleged deficiencies in the rules framing crimes against honor in Panamá. So, the State has not failed to comply with the general obligation to give domestic legal effects to the American Convention established in Article 2 thereof. 132. Likewise, the Court finds and appreciates that, after the events that led to the instant case, significant reforms were made to the regulatory framework of Panamá, as far as freedom of expression is concerned. 133. Indeed, in July 2005, the Law “prohibiting the application of penalties for contempt, enacting measures related to the right of reply, correction or answer, and adopting other provisions,”116 was published in the Official Gazette. Section 2 of such law provides for the right of correction and reply, and establishes the procedure to be followed,117 strengthening the protection of the right to freedom of expression. 114 Judgment No. SA-2 of the Juzgado Noveno de Circuito Penal del Primer Circuito Judicial de Panamá [Panamá First Court Circuit Criminal Circuit Court Number Nine], dated January 16, 2004 supra note 81, folio 1581. 115 Judgment No. SA-2 of the Juzgado Noveno de Circuito Penal del Primer Circuito Judicial de Panamá [Panamá First Court Circuit Criminal Circuit Court Number Nine], dated January 16, 2004 supra note 81, folio 1582. 116 National Assembly, Law No 22, of June 29, 2005, (Case File of Appendixes to the Motions, Pleadings and Evidence Brief, Book II, Appendix 10, folios 2461 to 2467). 117 National Assembly, Law No 22, of June 29, 2005, supra note 116, folios 2461 and 2462. In Section 2, it provides: