7. However, the Court’s case law, including this judgment, has been emphatic in maintaining that freedom of expression is not an absolute right, and that although Article 13 of the Convention prohibits prior censorship, it recognizes the possibility of establishing subsequent liability for the abusive exercise of this right, for example, to secure the rights or reputation of others. In other words, the Convention provides for the possibility of regulating and imposing sanctions or other subsequent liabilities with respect to those expressions that may affect the reputation and honor of individuals. At this point it is worth mentioning that the Court has recognized that Article 11 of the Convention, which recognizes the right to honor or reputation, imposes the State obligation to protect said legal interests. 8. Based on the foregoing, the case law of the Court has stated that, when there is a conflict between both rights, for example, when a person expresses opinions that attempt against a person’s honor, a weighting is necessary to determine whether the imposition of subsequent liabilities was appropriate. In this scheme of analysis, the Court has qualified in its case law that the restrictions must meet the following requirements: be established by law, respond to an objective established in the Convention, and be necessary in a democratic society. This test has served as a starting point for analysis in the Court’s case law in cases that require an analysis of the validity of a sanction imposed as a result of expressions that infringe upon the honor of individuals. However, this is not the only way to analyze whether a restriction on freedom of expression constituted a violation of Article 13 of the Convention. 10 The Court’s recent case law, reiterated in this case, has proposed a new form of analysis that allows a greater effectiveness of protection in cases such as this one. 9. In the case of Àlvarez Ramos v. Venezuela (2019), the Court addressed a particular assumption regarding the imposition of subsequent liabilities: the application of criminal sanctions regarding speeches of public interest that involved the conduct of public officials in the exercise of their duties. In the case, the victim was tried for having committed the crime of “ongoing aggravated defamation” for the publication of a journalistic piece that referred to the management of public resources by an official. The Court considered that in these cases “the State’s punitive response through criminal law is not appropriate under the convention to protect the honor of an official”. 11 Within its reasoning, the Court warned that the criminal response must be an exception, and that applying it in this type of speech limits freedom and prevents subjecting acts of corruption, abuse of authority, etc. to public scrutiny. In other words, based on this precedent, the Court considered that the Convention prohibits the imposition of a criminal sanction in the particular case addressed. 10. The Case of Palacio Urrutia reiterates the aforementioned thesis. It concluded that, given a speech of public interest, which constituted an opinion on the part of Mr. Palacio Urrutia regarding the actions of then President Rafael Correa in the exercise of his duties, the criminal sanction imposed on the victims violated their right to freedom of expression. The Court also developed some aspects that are equally relevant. In the first place, it recognized that the sanctions or civil responsibilities that are imposed in this type of case, although they are not per se outside the convention, like the criminal sanctions, must be duly reasoned, be proportional, and not be aimed at affecting freedom of expression of the person issuing said opinion, or of those who work in a media outlet. Thus, the imposition of Cf. Palacio Urrutia et al. v. Ecuador. Merits, Reparations and Costs. Judgment of November 24, 2021, par. 100-109. 10 Cf. Case of Álvarez Ramos v. Venezuela. Preliminary Objections, Merits, Reparations and Costs. Judgment of August 30, 2019. Series C No. 380, par. 121. 11 3