38 the truth. 153 In that same vein, the Court has found that the State has the duty to ensure that everything necessary is done to learn the truth about what happened and for those responsible to be punished, 154 and involving every State institution. 155 Furthermore, with regard to the principle of a reasonable time established in Article 8(1) of the American Convention, the Court has established that it is necessary to take into account three elements in order to determine the reasonableness of the time in which the proceedings are held: (a) the complexity of the case; (b) the procedural activity of the party concerned, and (c) the conduct of the judicial authorities. However, the pertinence of applying these three criteria to determine the reasonableness of the time of the proceedings depends on the circumstances of each case. 156 146. Based on the above-cited precedents, the Commission will analyze if in the instant case the Colombian State carried out a meaningful and diligent investigation within a reasonable time into the events described in the present report as a means to ensure the substantive rights to life and humane treatment, 157 and to ensure access to an effective judicial remedy for violations of human rights. 147. The Commission has proven that legal proceedings were instituted in the military and civilian criminal jurisdictions as a result of the events in the instant case, as were proceedings of a disciplinary and contentious administrative nature. 148. As far as military criminal justice is concerned, the Inter-American Court has expressed its opinion on the lack of suitability of the military criminal courts as a forum to examine, prosecute, and punish cases that concern human rights violations and has established that under the democratic rule of law this jurisdiction must have a restricted and exceptional scope and be designed to protect special juridical interests associated with the functions assigned by law to the military forces. Hence, it should only try military personnel for committing crimes or misdemeanors that, due to their nature, harm the juridical interests of the military system. 158 149. In the instant case, the investigation into the events remained in military criminal jurisdiction from January 12, 1999 until October 31, 2002, when the First Review Chamber of the Constitutional Court delivered Judgment T-932-02, with which jurisdiction was granted to the 153 I/A Court H.R., Case of García-Prieto et al. v. El Salvador. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 20, 2007. Series C, No. 168, par. 101. I/A Court H.R., Case of Bulacio v. Argentina. Judgment of September 18, 2003. Series C, No. 100, par. 114; I/A Court H.R., Case of the Rochela Massacre v. Colombia. Judgment of May 11, 2007. Series C No. 163, par. 146; I/A Court H.R., Case of the Miguel Castro-Castro Prison v. Peru. Judgment of November 25, 2006. Series C, No. 160, par. 382. 154 155 I/A Court H.R., Case of Cantoral-Huamaní and García-Santa Cruz v. Peru. Preliminary Objections, Merits, Reparations and Costs. Judgment of July 10, 2007. Series C, No. 167, par. 130; I/A Court H.R., Case of the Massacre of Pueblo Bello v. Colombia. Judgment of January 31, 2006. Series C, No. 140, par. 120; and I/A Court H.R., Case of Huilca Tecse v. Peru. Judgment of March 3, 2005. Series C, No. 121, par. 66. I/A Court H.R., Case of the Massacre of Pueblo Bello v. Colombia. Judgment of January 31, 2006. Series C, No. 140, par. 171. 156 157 I/A Court H.R., Case of González et al. (“Cotton Field”) v. Mexico. Judgment of November 16, 2009, par. 287; I/A Court H.R., Case of the Massacre of Pueblo Bello v. Colombia. Judgment of January 31, 2006. Series C, No. 140, par. 142. 158 I/A Court H.R., Case of the Massacre of Pueblo Bello v. Colombia. Judgment of January 31, 2006. Series C, No. 140, par. 189; I/A Court H.R., Case of Palamara Iribarne v. Chile, Judgment of November 25, 2005. Series C, No. 137, par. 124; I/A Court H.R., Case of the “Mapiripán Massacre” v. Colombia. Judgment of September 15, 2005. Series C, No. 134, par. 202; and I/A Court H.R., Case of Lori Berenson Mejía v. Peru, Judgment of November 25, 2004, Series C No. 119, 142.

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