proceeding was closed. As to the other presumed perpetrators, the Court confirms that in the competent authority determined that there were insufficient elements to establish the involvement of the other persons investigated in this case. 187. In view of the general assessment of the process, the Court finds that the State conducted several proceedings to elucidate the facts and punish those responsible. Regarding the final decision to acquit the presumed intellectual author, this decision was not questioned before this Court, either on grounds of breaching essential requirements, procedural fraud or fraudulent res judicata (supra para. 180). Therefore, in accordance with the particular circumstances of the case, it is evident that the State’s judicial system operated through the investigation of the facts and the determination of specific responsibilities, and was unable to conclude other responsibilities due to the deaths of two of the accused. However, should further evidentiary elements arise, this does not prevent the competent domestic authorities from deciding to continue with the investigation and establish the corresponding responsibility in accordance with domestic legislation. B.2. Reasonable time period 188. The concept of a reasonable period of time contemplated in Article 8 of the American Convention is closely linked to the notion of an effective, simple and prompt remedy envisaged in Article 25.283 This Court has indicated that the right to have access to justice is not exhausted by the processing of domestic proceedings, but must also ensure, within a reasonable period of time, the right of victims or their families to learn the truth about what happened and to sanction those responsible.284 The Court has also held that a reasonable period of time should be determined in relation to the duration of the entire procedure, from the first action until the final judgment is handed down, including any appeals that may be filed.285 189. At the same time, in its consistent case law the Court has established that four elements must be considered in order to determine whether this rule is fulfilled in each case: the complexity of the case; the conduct of the judicial authorities; the procedural activity of the interested party;286 and the “adverse effect of the duration of the proceedings on the judicial situation of the person involved.”287 190. In relation to the first element, this Court has taken into account several criteria for determining the complexity of a process. These include the complexity of the evidence, the number of parties or the number of victims involved in the proceedings, the time that has elapsed since the violation, the nature of the remedies embodied in the domestic legislation and the context in which the violation occurred.288 Similarly, the European Court has ruled 283 Cf. Case of Baldeón García v. Peru. Merits, Reparations and Costs. Judgment of April 6, 2006. Series C, No. 147, para. 155 and Case of Suárez Peralta, supra, para. 122. 284 Cf. Case of the 19 Tradesmen v. Colombia. Preliminary Objection. Judgment of June 12, 2002. Series C, No. 93, para. 188 and Case of García Lucero et al. v. Chile. Preliminary Objections Merits, Reparations and Costs. Judgment of August 28, 2013. Series C, No. 267, para. 121. 285 Cf. Case of Suárez Rosero v. Ecuador. Merits. Judgment of November 12, 1997. Series C, No. 35, para. The concept 71 and Case of López Álvarez v. Honduras. Merits, Reparations and Costs. Judgment of February 1, 2006. Series C, No. 141, para. 130. 286 Cf. Case of Suárez Rosero, supra, para. 72 and Case of Furlan and Family v. Argentina. Preliminary Objections, Merits, Reparations and Costs. Judgment of August 31, 2012. Series C, No. 246, para. 152. 287 164. Cf. Case of Valle Jaramillo et al., supra, para. 155 and Case of the Santo Domingo Massacre, supra, para. 288 Cf. Case of Genie Lacayo v. Nicaragua. Preliminary Objections. Judgment of January 27, 1995. Series C, No. 21, para. 78 and Case of Furlan and Family, supra, para. 156. 57

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