116 293. Even though more than ten years and eight years have elapsed since the events took place in La Granja and El Aro, respectively, some of the criminal proceedings remain open. The Court recognizes that the matters investigated by the domestic judicial bodies in relation to the massacres of La Granja and El Aro are complex. Despite this, concrete results have been achieved in the investigations and in the different criminal proceedings and, although insufficient, they have resulted in the sentencing of members of the Army, as well as members of paramilitary groups, for their participation in the events that gave rise to this case (supra para. 125(51) and 125(93)). Nevertheless, the Court observes that some of those involved have been tried and convicted in absentia. Moreover, in view of the scope of the events and the number of people involved, the means used and the results achieved are insufficient to comply with the provisions of the American Convention. Consequently, the Court considers that, in this case, in addition to examining the reasonableness of the time that has elapsed during the investigations, the State’s responsibility under Articles 8(1) and 25 of the Convention should be established by assessing the development and results of the different criminal proceedings; in other words, by assessing how effective the investigation of the facts has been in determining the truth of what happened, punishing those responsible, and repairing the violations committed to the detriment of the alleged victims.238 294. The massacres were perpetrated in the context of the internal armed conflict in Colombia; they encompassed a large number of victims – who lost their possessions or were executed and, in the case of El Aro, were compelled to carry out forced labor or displaced – and they occurred in a remote region, with difficult access, among other factors. However, even taking into account the complexity of the case, the effectiveness of the proceedings has been affected by several flaws in the investigation (supra para. 125(42), 125(43), 125(52), 125(87) and 125(93)). Hence, it is not possible to argue, as the State is trying to, that the investigations in the instant case were conducted within a reasonable time, given the complexity of having to deal with the “macro-criminality” implicit in the facts and the limited procedural activity of the petitioners in the domestic proceedings, particularly in the criminal proceedings where they are unable to bring a civil action (supra para. 282(ii)(a) and (b)). 295. In this regard, the representatives indicated that Colombian criminal legislation expressly prevented the claimant for civil injury from participating at the pre-trial investigation stage, a situation that changed as of April 3, 2002, when the Colombian Constitutional Court issued Judgment C-228, ordering this participation. Furthermore, the limited participation by the next of kin in the criminal proceedings, either as claimants for civil injuries or as witnesses, is also a result of their displacement and the fear of participating in these proceedings owing to the death or threats against people who took part in them or filed them, such as Jesús Valle Jaramillo, or several prosecutors who left the country (supra para. 125(95)). 296. In this respect, the Court has indicated that during the investigation process and the judicial proceedings, the victims of human violations or their next of kin should have ample opportunities to take part and be heard in the clarification of the 238 Cf. Case of the Pueblo Bello Massacre, supra note 9, para. 170; and Case of the “Mapiripán Massacre”, supra note 8, para. 222.