33 the reasonable time for conducting them, because to date no one has been punished, and the investigation has not concluded, and this has also given rise to impunity. Lastly, the Commission indicated that the competent authorities did not initiate, ex officio, an investigation concerning torture after it had been found that Mr. Portugal’s remains bore injuries that were compatible with acts of torture. Hence, the Commission considered that the State failed to investigate, prosecute and punish those responsible for the alleged torture to which Mr. Portugal was subjected, which constitutes a violation of Articles 1, 6 and 8 of the Inter-American Convention to Prevent and Punish Torture. 124. The representatives endorsed most of the Commission’s allegations. Regarding the criminal investigation proceedings, they added that Panama failed to comply with its obligation to investigate, because it requested the application of a statute of limitations to the criminal action and then recommended a stay of proceedings in the case, despite the fact that it involved grave human rights violations. Regarding the reasonable time period, the representatives indicated that the proceedings were relatively simple, because there was irrefutable evidence of the existence of a context of political violence, the practice of forced disappearance, and the direct participation of State agents. In addition, the delays were not due to an obstructive attitude by the alleged victim’s next of kin but, to the contrary, it was the family that filed the complaint when it was politically possible, provided testimony and indicated possible witnesses who could throw some light on the situation for the investigator. 125. The State indicated that it was not possible to infer a violation of the right to a fair trial and to judicial protection from the alleged facts. To the contrary, the next of kin did not avail themselves of the complaint mechanism (querella), which is a remedy available under the Panamanian juridical order to safeguard judicial protection and rights, which allows the next of kin to intervene directly in the preliminary proceedings and the procedural actions relating to the criminal act. 126. Based on the above, the Court must determine whether the State violated the rights established in Articles 8(1) and 25(1) of the Convention, in relation to Article 1(1) thereof. To this end, the Court has established that “[c]larification of whether the State has violated its international obligations owing to the actions of its judicial organs may lead the Court to examine the respective domestic proceedings.”81 The Court will therefore examine the measures taken before the criminal competence in light of the standards established in the American Convention in order to determine whether there was a violation of judicial guarantees and the right to judicial protection in the context of the investigations to clarify the facts of this case. Before proceeding to examine whether the State has complied with its convention obligations, it is pertinent to describe the facts on which the allegations are based. a) Period from 1990 to 2000 127. As already indicated (supra para. 94), on May 10, 1990, Patria Portugal filed a complaint before the Office of the First Superior Prosecutor of the First Judicial District of Panama indicating that, on May 14, 1970, her father had been detained and disappeared, and that it was not possible to file a complaint before the Attorney General’s Office then, 81 Cf. “Street Children” (Villagrán Morales et al.) v. Guatemala. Merits. Judgment of November 19, 1999. Series C No. 63, para. 222; Case of García Prieto et al., supra note 10, para. 109, and Case of Ximenes Lopes v. Brazil. Merits, reparations, and costs. Judgment of July 4, 2006. Series C No. 149, para. 174.