174. The Court, thus, holds that it is not necessary to examine other phases or aspects of the proceedings, nor to scrutinize the factors that led to the delays209 since it is evident that the most extensive and relevant delays were due to unjustified State conduct. After many years, their families still do not know the whereabouts of the two men. Their disappearances, as well as the extrajudicial executions of the three women, have not been clarified nor have the corresponding responsibilities been determined. 175. Therefore, Uruguay, by not investigating within a reasonable period, did not comply with Article 8 of the Convention. B.2.4 Failure to comply with the right to the truth 176. The Court has held that “everyone, including the next of kin of the victims of serious human rights violations, has the right to know the truth. Consequently, the victims’ next of kin and society in general should be informed of everything that happened regarding such violations.”210 The right to the truth is autonomous and is broad-based. Depending on the context and circumstances of a case, the violation of this right may be related to other rights expressly established in the American Convention,211 such as the rights to judicial guarantees and to judicial protection, recognized in Articles 8 and 25,212 or the right to access to information, protected by Article 13. In this case, the Court does not find a basis to examine this latter provision.213 177. As the United Nations High Commissioner for Human Rights has expressed, “the right to the truth implies knowing the full and complete truth as to the events that transpired, their specific circumstances and who participated in them, including knowing the circumstances in which the violations took place, as well as the reasons for them.”214 Therefore, it is important that, depending on the case, the inquiries undertaken to determine what occurred, for example, take into consideration the perspective of gender or the political reasons for the human rights violations. In cases of forced disappearance, The case law of the Court has considered four elements to determine whether there is compliance with the judicial guarantee of a reasonable period, that is: (a) the complexity of the matter; (b) the procedural activity of the interested person; (c) the conduct of the judicial authorities, and (d) the harm caused to the legal situation of the person involved in the process (cf. Case of Genie Lacayo v. Nicaragua, para. 77; Case of Valle Jaramillo et al. v. Colombia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 192, para. 155 and Case of Bedoya Lima et al. v. Colombia, para. 142). The examination of every one of those elements was not necessary in the latter case. 209 Cf. Case of Trujillo Oroza v. Bolivia. Reparations and costs. Judgment of February 27, 2002. Series C No. 92, para. 100 and Case of Herzog et al. v. Brazil, para. 328. Similarly, Case of Barbosa de Souza et al. v. Brazil, para. 134. 210 211 86. Cf. Case of Trujillo Oroza v. Bolivia, para. 100 and Case of Garzón Guzmán et al. v. Ecuador, para. Cf. Case of Velásquez Rodríguez v. Honduras. Merits, para. 181 and Case of Guachalá Chimbo et al. v. Ecuador. Merits, Reparations and Costs. Judgment of March 26, 2021. Series C No. 423, para. 213. 212 It is important to note the difference in the circumstances of this case compared to others, for example, the Case of Gómes Lund et al. The Court observes that the right to know the truth is related to the request of the next of kin to receive certain information. Cf. Case of Gomes Lund et al. ("Guerrilha do Araguaia") v. Brazil. Preliminary Objections, Merits, Reparations and Costs. Judgment of September 24, 2010. Series C No. 219, para. 200). Those characteristics cannot be assumed in this case. 213 United Nations. Council of Human Rights (2009) Report of the Office of the High Commissioner for Human Rights. The Right to the Truth. Document E/CN.4/2006/91, para. 59. 214 47

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