humane treatment derived from the phenomenon of death row, it is necessary to analyze the personal and particular circumstances of the case in order to assess whether a particular treatment or punishment reached the minimum level of severity to qualify as cruel, inhuman or degrading.131 Likewise, the European Court of Human Rights,132 the Universal Human Rights System 133 and some national courts134 warn that the so-called "death row" causes a violation to the right to humane treatment due to the anguish in which the persons condemned to death find themselves, a situation that generates psychological trauma due to the present and increasing manifestation of the execution of the capital penalty,135 therefore, it is considered as cruel, inhuman and degrading treatment. 95. The Court emphasizes that the manner in which a death sentence is imposed may constitute a factor that determines its incompatibility with the provisions of Article 5 of the American Convention.136 The Court observes that Messrs. Rodríguez Revolorio, López Calo and Archila Pérez were sentenced to death in the context of a criminal proceeding in which there were clear violations of Articles 4(2) and 9 of the Convention, and in violation of the right to appeal the judgment provided for in Article 8(2)(h) of the American Convention (see infra section VIII.3.b.3). The Court considers that the criminal proceedings to which Mr. Rodríguez Revolorio, Mr. López Calo and Mr. Archila Pérez were subjected, which also resulted in the imposition of the death penalty, could have caused them profound suffering, anguish, anxiety, frustration and stress, which could even have led to some type of post-traumatic stress disorder, as has happened in other cases of persons sentenced to death.137 In addition to the above, the Court has already indicated that the prison conditions to which they were subjected were incompatible with the standards referred to in the previous chapter. 96. For these reasons, the Court concludes that Messrs. Rodríguez Revolorio, López Calo and Archila Pérez underwent serious psychological suffering resulting from the anguish of remaining on "death row" after a procedure that was significantly flawed, in prison conditions incompatible with the standards of the Convention, which violated their right to physical, mental and moral integrity, contained in Article 5(1) of the American Convention, and constituted cruel, inhuman and degrading treatment, contrary to Article 5(2) of the American Convention, all in relation to Article 1(1) of the same instrument. Cf. Case of Vera Vera et al. v. Ecuador. Preliminary Objection, Merits, Reparations and Costs. Judgment of May 19, 2011. Series C No. 226, para. 76. See also, ECtHR, Case of Ireland v. the United Kingdom, no. 5310/71, Judgment of January 18, 1978, para. 162; Case of Jalloh v. Germany [GC], no. 54810/00, Judgment of July 11, 2006, para. 67, and Case of Bouyid v. Belgium [GC], no. 23380/09/03, Judgment of September 28, 2015, para. 86. 132 Cf. ECtHR, Case of Öcalan v. Turkey [GC] no. 46221/99, paras. 166-169. 46221/99, paras. 166-169; Case of Bader and Kanbor v. Sweden, no. 13284/04, paras. 42-48. 133 United Nations. Report of the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment. 9 August 2012. A/67/279, para. 42. The death row phenomenon is defined as: "(...) It consists of a combination of circumstances that produce severe mental trauma and physical deterioration in prisoners under sentence of death. Those circumstances include the lengthy and anxiety-ridden wait for uncertain outcomes, isolation, drastically reduced human contact and even the physical conditions in which some inmates are held. Death row conditions are often worse than those for the rest of the prison population, and prisoners on death row are denied many basic human necessities (...)". See also, HRC, Larranaga v. Philippines, UN Doc: CCPR/C/87/D/1421/2005 (2006), para. 7.11; Mwamba v. Zambia, UN Doc: CCPR/C/98/D/1520/2006 (2010), para. 6.8. 134 Judgment of the Supreme Court of Zimbabwe of June 24, 1993 in Catholic Commissioner for Justice and Peace in Zimbabwe v. Attorney General (4) SA 239 (ZS); Supreme Court of Uganda in Attorney General v. Susan Kigula and 417 others (Constitutional Appeal No. 3 of 2006), 2009. AG v. Susan Kigula & 417 others, Supreme Court of Uganda (2009); Catholic Commission for Justice and Peace in Zimbabwe v the Attorney General & Others, Supreme Court of Zimbabwe (1993), 2LRC 277; Godfrey Mutiso v. Republic, Court of Appeal of Kenya (2010). See also US v Burns, Supreme Court of Canada, 2001 SCC 7, paras 118-123. 135 Cf. ECtHR, Case of Soering v. the United Kingdom [GC], no. 14038/88, Judgment of July 7, 1989, paras. 56, 81 and 111. 136 Cf. ECtHR, Case of Soering v. the United Kingdom [GC], supra, para. 106, and Case of Shamayev and others v. Georgia and Russia, no. 36378/02, Judgment of April 12, 2005, para. 333. 137 Cf. Case of Raxcaco Reyes v. Guatemala, supra, and Case of Hilaire, Constantine and Benjamin et al. v. Trinidad and Tobago, supra. 131 29