defamation and, in any case, criminal law should only be applied in the most serious cases”. 36 The European Court decided, in the Case of Castells v. Spain, that it continues “to be possible for the competent State authorities to adopt, in their capacity as guarantors of public order, measures, including criminal measures, aimed at reacting appropriately and without excesses to defamatory accusations unfounded or made in bad faith”. 37 It thus follows from the position of said Court that criminal sanctions for defamation could be appropriate in limited circumstances, establishing that their application must be made in matters related to the guarantee of public order that are especially serious, and not to protect a person's reputation. 38 32. The aforementioned standards and criteria suggest the existence of a trend: that opinion discourse dealing with matters of public interest enjoys special protection, and that the criminalization of defamation is not the only measure, nor the ideal measure, to protect honor and reputation. By contrast, the recognition of civil proceedings or the exercise of the right of rectification or response are noted as adequate mechanisms to protect honor, being the most favorable approach for freedom of expression. An advanced interpretation of Article 13 of the American Convention, in accordance with the factual realities of our times and the progress of regional and international law on the matter, allows the scope of freedom of expression to be interpreted more broadly than what is indicated in this case, establishing that the criminalization of opinion speech and speech in the public interest is prohibited by the American Convention, with the civil route and the right of reply being the appropriate means for the protection of honor and reputation. IV. CONCLUSION 33. The judgment represents a point of maturation in the case law on freedom of expression, as it reaffirms the interpretation previously made in the Case of Álvarez Ramos. This last judgment extended the scope of protection to freedom of expression by prohibiting the use of criminal law to punish opinion speeches that refer to the acts of public officials carrying out their duties, and that address issues of public interest. In addition to this, in the specific case, reflections of a general nature were made, and guarantees of non-repetition were established, which are based on the belief that the States must adopt alternative mechanisms to criminal proceedings for public officials to appeal against acts that they consider violate their honor or dignity. This aspect opens the door to reflect on the need and importance of anti-SLAPP measures, as a means to avoid strategic demands whose purpose is to censor critical opinion, and the need to continue strengthening the robust protection of freedom of expression granted by the American Convention, by strengthening the protection of opinion speech and freedom of expression on matters of public interest. Eduardo Ferrer Mac-Gregor Poisot Judge 36 Cf. UN Human Rights Committee. General Observation nº 34. Article 19. Freedoms of opinion and expression, September 12, 2011, par. 47. 37 ECHR. Castells v. Spain, April 23, 1992, par. 46. 38 Report of Toby Mendel, par. 65. 10