1. General Considerations on the applicable guarantees and the principle of judicial independence 46. The Commission recalls that both organs of the Inter-American system have indicated that the guarantees established in Article 8 of the American Convention are not limited to criminal proceedings, but apply to processes of other natures. 21 Specifically, when dealing with proceedings involving imposition of sanctions, both bodies have indicated that they apply in an analogous manner, the guarantees established in Article 8.2 of the American Convention. 22 Likewise, the principle of legality is applicable to disciplinary proceedings that are "an expression of the punitive power of the State" since they infringe or alter individual rights as a consequence of unlawful conduct. 23 47. In the present case, the alleged victim was dismissed from his post as member of the Supreme Electoral Tribunal as a result of a decision of the legislative body that had the stated purpose of rectifying an appointment allegedly incompatible with the applicable law. In this sense, the punitive nature of this particular action by the State and the consequent determination of the applicable guarantees do not derive, as in other cases, from the formal nature of the process. For this determination, the Commission refers to the decision by the Inter-American Court in the Case of Camba Campos et al. v. Ecuador regarding the true punitive nature of Resolution 25-160. In the words of the Court: "the supposed illegality in the appointment constituted only a justification to impose a de facto sanction".24 48. In this regard, the Commission considers that the present case must be analyzed in the light of the due process guarantees established in Article 8 of the Convention and the principle of legality established in Article 9 of the same instrument. 49. In addition, the IACHR emphasizes that disciplinary proceedings against justice operators must be carried out in a manner compatible with the principle of judicial independence. The organs of the InterAmerican system have interpreted the principle of judicial independence in the sense of incorporating the following guarantees: adequate appointment process, tenure in office and guarantee against external pressures.25 Specifically, as is relevant in the present case, with respect to the enhanced guarantees to ensure tenure, the Court has indicated that "[they] result in the subjective right of judges to be dismissed exclusively for the reasons permitted, either by a proceeding that complies with judicial guarantees or because their mandate has terminated”.26 When the permanence of the judges in their position is arbitrarily affected, "the right to judicial independence enshrined in Article 8.1 of the Convention is violated."27 IACHR, Report No. 65/11, Case 12.600, Merits, Hugo Quintana Coello and others “Justices of the Supreme Court of Justice”, Ecuador, March 31, 2011, para. 102; I/A Court H.R., Case of Baena Ricardo et al. v. Panama. Merits, Reparations and Costs. Judgment of February 2, 2001. Series C No. 72, paras. 126-127; Case of the Constitutional Court v. Peru. Merits, Reparations and Costs. Judgment of January 31, 2001. Series C No. 71, paras. 69-70; and Case of López Mendoza v. Venezuela. Merits, Reparations, and Costs. Judgment of September 1, 2011. Series C No. 233, para. 111. 22 IACHR. Access to Justice as a Guarantee of Economic, Social, and Cultural Rights. A Review of the Standards Adopted by the Inter-American System of Human Rights. OEA/Ser.L/V/II.129. September 7, 2007, paras. 98-123; and Case No. 12.828, Report 112/12, Marcel Granier and others, Venezuela, Merits, November 9, 2012, para. 188; I/A Court H.R., Case of Baena Ricardo et al. v. Panama. Merits, Reparations and Costs. Judgment of February 2, 2001. Series C No. 72, paras. 126-127. 23 IACHR, Report No 99/11, Case 12.597, Merits Report, Miguel Camba Campos and others “Members of the Constitutional Tribunal”, Ecuador, July 22, 2011, para.94; I/A Court H.R., Case of López Lone et al. v. Honduras. Preliminary Objection, Merits, Reparations and Costs. Judgment of October 5, 2015. Series C No. 302, para. 257 and Case of Maldonado Ordóñez v. Guatemala. Preliminary Objection, Merits, Reparations and Costs. Judgment of May 3, 2016. Series C No. 311, para. 89. I/A Court H.R., Case of Baena Ricardo et al. v. Panama. Merits, Reparations and Costs. Judgment of February 2, 2001. Series C No. 72, paras. 106 and 108. 24 I/A Court H.R., Case of the Constitutional Tribunal (Camba Campos et al.) v. Ecuador. Preliminary Objections, Merits, Reparations and Costs. Judgment of August 28, 2013. Series C No. 268, para.130. 25IACHR, Report on the Guarantees for the Independence of Justice Operators. Towards Strengthening Access to Justice and the Rule of Law in the Americas, December 5, 2013, paras. 56, 109 and 184, I/A Court H.R., Case of López Lone et al. v. Honduras. Preliminary Objection, Merits, Reparations and Costs. Judgment of October 5, 2015. Series C No. 302, para. 191. 26 I/A Court H.R., Case of López Lone et al. v. Honduras. Preliminary Objection, Merits, Reparations and Costs. Judgment of October 5, 2015. Series C No. 302, para. 192. 27 I/A Court H.R., Case of López Lone et al. v. Honduras. Preliminary Objection, Merits, Reparations and Costs. Judgment of October 5, 2015. Series C No. 302, para. 192. 21 9