guaranteeing its swift resolution and execution.49 In rulings that are also of relevance to this case, the European Court has stated labor disputes, by their very nature, demand particularly swift resolution.50 50. Likewise, the right to judicial protection entails the State’s duty of offering an effective judicial remedy against acts that violate the rights of persons under their jurisdiction. 51 The Inter-American Court has emphasized the need for domestic proceedings to guarantee genuine access to justice in order to determine any disputed right. 52 It has also ruled that their effectiveness presupposes that, in addition to the formal existence of remedies, they must be capable of responding to or resolving violations of rights enshrined in the Convention, in the Constitution, or in law.53 2. Analysis of the case 51. As indicated in the established facts, the labor proceedings arising from the occupational sickness compensation claim made against the company Cacique Camping S.A. began on June 30, 1988, before Labor Tribunal No. 3, and they came to an end on August 16, 2000, when the Supreme Court of Justice of the Province of Buenos Aires rejected the appeals filed by Mr. Spoltore against the first-instance judgment that had rejected his compensation claim. In other words, the proceedings as a whole lasted for 12 years, 1 month, and 16 days. 52. In the following paragraphs, the IACHR will analyze that period of time in light of the elements commonly used for such determinations and the relevant standards referred to in the previous section. 2.1 Complexity of the matter 53. Regarding the complexity of the matter, the Commission notes that effectively, the Argentine State argued the case’s complexity as a justification for the delay. Specifically, the State spoke of the matters addressed by the proceedings. It also stated that, in addition to the respondent and the plaintiff, the proceedings involved three insurance companies summoned to appear as third-part respondents, one of which declared a corporate reorganization; that all the formalities had to be reported to all the parties at trial; and that all the parties were entitled to file objections and remedies and that they did so. The State added that various formalities were challenged, repeated, or delegated to experts’ offices in another jurisdiction. The Commission will analyze whether the labor proceedings referred to in this case can be considered complex in light of the elements that the inter-American system has previously used to assess such situations. 54. The Commission first notes that the case involved labor proceedings to determine whether the company was required to provide Mr. Spoltore with compensation. Nothing in the case file indicates that, in terms of their regulations or in practice, such proceedings are particularly complex. On the contrary, in previous cases dealing with civil actions for damages between private citizens in Argentina, the Inter-American Court has ruled that the nature of civil proceedings indicates that they do not entail legal or probative aspects or discussions that would suggest that they are inherently complex. 54 Neither did the State of Argentina specifically explain what aspects of a labor proceeding such as the one at hand would have made it complex. Thus, the Commission believes that the nature of the case does not inherently imply complicated proceedings. 55. Second, the Commission notes that the time that passed between the alleged facts and Mr. Spoltore’s filing of his suit was reasonably short, in that he left the company in 1987 and the suit was filed the 49 I/A Court H. R. Case of Furlan and Family v. Argentina. Preliminary Objections, Merits, Reparations, and Costs. Judgment of August 31, 2012. Series C No. 246, para. 196. 50 European Court of Human Rights. Vocaturo v. Italy. Judgment of 24 May 1994. Application No. 11981/95, § 17. 51 IACHR Report No. 42/14. Case 12.453. Merits. Olga Yolanda Maldonado Ordóñez. Guatemala. July 17, 2014, para. 62. 52 I/A Court H. R. Case of the Dismissed Congressional Employees (Aguado Alfaro et al.) v. Peru. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 24, 2006, Series C No. 158, para. 107; and Case of the Ituango Massacres v. Colombia. Judgment of July 1, 2006, Series C No. 148, para. 365. 53 I/A Court H. R. Case of Abrill Alosilla et al. v. Peru. Interpretation of the Judgment on Merits, Reparations, and Costs. Judgment of November 21, 2011. Series C No. 235, para. 75. Embedded citations in the original text have been omitted. 54 I/A Court H. R. Case of Mémoli v. Argentina. Preliminary Objections, Merits, Reparations, and Costs. Judgment of August 22, 2013. Series C No. 265. 9