79 appropriate penalties has been frustrated; to the extent that the legal consequences of the law regarding the right to judicial guarantees are incompatible with the [A]merican Convention [on] Human Rights.281 To summarize, the unlawfulness of an amnesty law enacted for the benefit of military and police officials who committed [serious violations of human rights], whom enjoy impunity during de facto regimes, has been declared by courts, of both the international community and the States that went through similar processes experienced by Uruguay during the same period in time. Such rulings, given the similarity with the issue under analysis and the relevance they have had, could not be ignored in the examination of the constitutionality of Law [No.] 15.848 and have been taken into account by the Corporation to issue the present ruling.282 220. The Supreme Court of Justice in Honduras held that the decrees of 19987 and 87-91 of amnesty were unconstitutional and held that Section 205.16 of the Honduran Constitution grants Congress the power to concede amnesty for political crimes and those in relation; however, that provision does not give the authority to grant this benefit for crimes that were aimed at “threatening the existence and internal state of security, the system of government and citizen's rights.” For the Supreme Court, the Decree199-87 and Decree 87-91 "serve only to incorporate the behavior of the military in the form of a political offense, in reality being that the alleged crimes committed by the military were performed under the cover that they were an act of service or because of it [...]." With this, the Honduran Supreme Court declared its unconstitutionality based on the merits, and therefore, the inapplicability of Decree No. 199-87 issued on December 11, 1987, and No. 87-91 issued on June 24, 1991 that provided for unconditional amnesty.283 221. Furthermore, the Constitutional Chamber of the Supreme Court of Justice of El Salvador declared the legal impossibility of implementing the Law on General Amnesty for the Consolidation of Peace in cases of gross violations of human rights, and thus opened the possibility for criminal judges, upon hearing specific cases of human rights violations that occurred during the internal armed conflict, to consider the inapplicability Amnesty Law. 284 222. The Constitutional Court of Colombia, in various cases, has noted the obligation to avoid the application of domestic amnesty provisions in cases of serious human rights violations: Those such as the laws of final measure that impede access to justice, the blank amnesties for any crime, the self-amnesties (the criminal benefits which the legitimate and illegitimate holders of power grant themselves and whom were accomplices in the crimes committed), or whichever other form it takes so as to prevent victims from a obtaining an effective judicial remedy to make their rights count, have been considered as being in violation of the international 285 obligation of States to promote legal remedies for the protection of human rights.                                                          281 Supreme Court of Justice of Uruguay, Case of Nibia Sabalsagaray Curutchet, supra note 163, Considering clause III.8, para. 11. 282 Supreme Court of Justice of Uruguay, Case of Nibia Sabalsagaray Curutchet, supra note 163, Considering clause III.8, para. 15. 283 Supreme Court of Justice of the Republic of Hondorus, captioned orders – “RI20-99 – Unconstituitonality of Decree Number 199-87 and of Decree Number 87-91”, June 27, 2000. 284 Constitutional Chamber of the Supreme Court of Justice of El Salvador, Judgment 24-97/21-98, of September 26, 2000. 285 Constitutional Court of Colombia, Revision of the Law 742, of June 5, 2002, Case file No. LAT223, Judgment C-578/02, of July 30, 2002, section 4.3.2.1.7.