“The National Congress of Honduras exercises considerable control over the judiciary, which is incompatible with the principle of separation of powers and the independence of the judiciary, fundamental elements of every democracy and the rule of law.” 40 F. Purported harassment and threats against the alleged victims 46. In December 2012, Justice Gutiérrez Navas reported that he had received a death threat by telephone after he appeared on a television program. He stated: “They called and told me that if I continued down that path, my life would be in danger.” 41 Due to the fear of suffering an attack on his life and integrity and on that of his family, the alleged victim left the country for a time and sought political asylum in Spain. 42 47. On October 13, 2014, while the alleged victim was working as a university professor, he received an anonymous package that contained a keepsake from the end of the novena held for the death of his father, which had taken place in 2012. Mr. Gutiérrez Navas reported the incidents to the Committee of Relatives of the Detained–Disappeared in Honduras. 43 48. On February 21, 2013, one of Justice Cruz Sequeira’s daughters was the target of a car chase, and later the home of the alleged victim’s family was surveilled at night by unidentified subjects in a dark vehicle. Mrs. Cruz Sequeira reported the incidents and requested security measures from the National Human Rights Commission, an agency that for a time assigned her a police officer for protection. 44 49. The petitioners alleged that the State authorities failed to take any steps to investigate or afford protection in response to the incidents that were reported. 45 IV. ANALYSIS OF LAW A. Right to judicial guarantees, principle of legality, principle of judicial independence and judicial protection, and political rights 1. General considerations regarding applicable guarantees 50. The Commission recalls that both bodies of the inter-American system have indicated that the guarantees set forth in Article 8 of the American Convention are not confined to criminal proceedings but are applicable to other types of proceedings as well. 46 Specifically, both bodies have indicated that the guarantees for criminal proceedings apply by analogy to sanctions proceedings, as these involve the exercise of the State’s punitive power. 47 Given that in the instant case the alleged victims were removed from office as justices of the Annex 31. United Nations Special Rapporteur on the independence of judges and lawyers, Press release [in Spanish] of January 29, 2013. Annex to the petitioners’ brief of November 20, 2018. 41 Annex 32. Press report, Proceso Digital: Por amenazas salió del país ex magistrado José Antonio Gutiérrez Navas, available at https://proceso.hn/por-amenazas-salio-del-pais-ex-magistrado-jose-antonio-gutierreznavas/#:~:text=Tegucigalpa%2D%20El%20ex%20magistrado%20de,amenazas%20por%20la%20v%C3%ADa%20telef%C3%B3nica. Annex to the petitioners’ brief of November 20, 2018. 42 Annex 33. Press report, La Tribuna: Ex magistrado abandona el país por amenaza de muerte, December 18, 2012. Annex to the petitioners’ brief of November 20, 2018. 43 Annex 34. Complaint to COFADEH on August 19, 2014. Annex to the petitioners’ brief of November 20, 2018. 44 Annex 35. Complaint by Justice Rosalinda Cruz to the National Human Rights Commission, February 22, 2013. Annex to the petitioners’ brief of November 20, 2018. 45 Petitioners’ brief of November 20, 2018. 46 IACHR, Report No. 65/11, Case 12.600, Merits, Hugo Quintana Coello and Others, “Justices of the Supreme Court,” Ecuador, March 31, 2011, par. 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, par. 111. 47 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 et al., Venezuela, Merits, November 9, 2012, par. 188; IACHR, Report No. 42/14, Case 12.453, Merits, Olga Yolanda Maldonado Ordoñez, Guatemala, July 17, 2014, par. 69; 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. 40 11