after February 25, 2000, the date on which Guatemala ratified the Inter-American Convention on Forced Disappearance of Persons (supra paras. 15 and 16). However, the investigations and convictions handed down in this case have focused on the crime of “murder,” which, as has been established (supra para. 203), does not cover all dimensions of the acts that took place during the massacres. 227. Thus, the Court finds that the lack of investigation of the allegations of torture, forced disappearance, rape, and slavery and involuntary servitude in the context of the internal armed conflict in Guatemala represents a failure to comply with the State’s obligations regarding grave human rights violations, and contravenes non-derogable norms (jus cogens)307 under which Guatemala has a duty to investigate and punish those practices, pursuant to the American Convention and, additionally in this case, in light of the Convention against Torture, the Convention of Belém do Pará, and the Convention on Forced Disappearance. 228. Based on the foregoing, the State must open, ex officio and without delay, a serious, impartial and effective investigation into all the facts of the massacre, not only those relating to the violation of the right to life. Thus, the Court finds that the State has violated the rights recognized in Articles 8(1) and 25(1) of the American Convention, in relation to Article 1(1) thereof, and that it failed to comply with the obligation to investigate set forth in Articles 1, 6 and 8 of the Convention against Torture, 7(b) of the Convention of Belem do Pará, and I(b) of the Convention on Forced Disappearance of Persons (infra para. 237). B.6. Reasonable time for the investigation 229. Regarding the overall duration of the proceedings, this Court has indicated that the “reasonable time” to which Article 8(1) of the Convention refers must be assessed in relation to the total duration of the proceedings until the final judgment is handed down.308 The right of access to justice means that the dispute must be settled within a reasonable time,309 because an extended delay may in itself constitute a violation of judicial guarantees.310 The lack of State response is a decisive element when assessing whether Articles 8(1) and 25(1) of the American Convention have been violated.311 230. In this regard, the Court has usually considered the following elements in order to determine the reasonableness of the time: (a) complexity of the matter; (b) procedural activity of the interested party; (c) conduct of judicial authorities, and (d) effects on the legal situation on the person involved in the proceedings. However, the Court observes that approximately 32 years have passed since the massacre in the Río Negro chapel took place, and 30 years since the Xococ, Pacoxom, Los Encuentros and Agua Fría massacres. As already indicated in this Judgment, the grave human rights violations that were committed during these massacres must be investigated ex officio. Guatemala has been a State Party 307 Cf. Case of Goiburú et al. v. Paraguay, supra, para. 128, and Case of the Dos Erres Massacre v. Guatemala, supra, para. 140. 308 Cf. Case of Suárez Rosero v. Ecuador. Merits. Judgment of November 12, 1997. Series C No. 35, para. 71, and Case of the Dos Erres Massacre v. Guatemala, supra, para. 132. 309 Cf. Case of Suárez Rosero v. Ecuador, Merits, supra, para. 71, and Case of the Dos Erres Massacre v. Guatemala, supra, para. 132. 310 Cf. Case of Hilaire, Constantine and Benjamin et al. v. Trinidad and Tobago, supra, para. 145, and Case of the Dos Erres Massacre v. Guatemala, supra, para. 132. 311 Cf. Case of García Pietro et al. v. El Salvador, supra, para. 115, and Case of the Dos Erres Massacre v. Guatemala, supra, para. 132. 81