18. However, subsequently, the judgment states that the prohibition of the use of criminal law to sanction crimes against honor is only the first element of the protection of freedom of expression since, as stated in the text, it is possible that a civil sanction is equally or more inhibitory of speech when it imposes sanctions that are disproportionate. In this case, it was demonstrated how the imposition of a sentence that implied the payment of thirty million dollars by Mr. Palacio Urrutia and the directors of El Universo newspaper, and ten million dollars by the El Universo Limited Company, had an impact on the exercise of freedom of expression of the victims in the case, and on the rest of the workers of the media outlet in which they worked. From the statements presented in the process, it was inferred that the media employees also suffered an impact on their work as a result of the criminal process and the sanction that was imposed on the victims. Hence, the judgment sanctioned the violation of freedom of expression due to the imposition of the disproportionate civil sanction. 18 19. In this regard, it should be noted that the imposition of disproportionate civil penalties in proceedings involving violations of the right to honor have been sanctioned by the European Court of Human Rights (hereinafter, "European Court") as causes of the violation of freedom expression. In the Case of Tolstoy Miloslavsky v. the United Kingdom, said Court recognized that even in those cases where there is a seriously defamatory statement for which significant compensation is due, the sanctions imposed should be assessed in accordance with the right to freedom of expression, and therefore, should maintain a proportional relationship with the reputational damage suffered. In this framework of analysis, in the face of a disproportionate sanction for an act of defamation, there is a violation of Article 10 of the European Convention on Human Rights. 19 In a similar logic, in the Case of Filipović v. Serbia, it understood the following: “the amount of compensation awarded must “bear a reasonable relationship of proportionality to the ... [moral] ... injury ... suffered” by the plaintiff in question (see Tolstoy Miloslavsky v. the United Kingdom, judgment of 13 July 1995, Series A no. 316-B, § 49; see also Steel and Morris v. the United Kingdom, no. 68416/01, § 96, ECHR 2005, where the Court held that the damages “awarded ... although relatively moderate by contemporary standards ... [were] ... very substantial when compared to the modest incomes and resources of the ... applicants ... ” and, as such, in breach of the Convention).” 20 20. In a similar vein, in the case of Independent Newspaper v. Ireland, the European Court indicated that the determination of high compensation for damages require a thorough examination of proportionality as restrictions on freedom of expression, even when they have not shown a chilling effect. In addition, it was indicated that in cases where a high amount of compensation is established, it should also be evaluated whether there are guarantees that allow protection against compensation that is disproportionate with respect to the established amount and damage to reputation. 21 In the specific case, the violation of freedom of expression was determined due to the absence of adequate guarantees that would prevent disproportionate compensation by a jury. 22 Cf. Palacio Urrutia et al. v. Ecuador. Merits, Reparations and Costs. Judgment of November 24, 2021, par. 121126. 18 19 Cf. ECHR. Tolstoy Miloslavsky v. The United Kingdom, Judgment of July 13, 1995. 20 ECHR, Filipovic v. Servia, November 20, 2007, par. 56. 21 Cf. ECHR. Independent Newspapers (Ireland) Limited. c. Ireland, June 15, 2017, par. 113. 22 Cf. ECHR. Independent Newspapers (Ireland) Limited. c. Ireland, June 15, 2017, par. 132. 6