the crime. Indeed, the lead Prosecutor in the preliminary investigation concluded based on the evidence gathered that, “the murder of journalist and educator Nelson Carvajal Carvajal was because of, or for reasons relating to, his profession, especially given the type of exposé reporting he did”. For this reason, he ordered the transfer of the investigation to the regional justice system. The Single Criminal Court of the Specialized Circuit of Neiva likewise affirmed that, “it is concluded from the testimony of numerous witnesses at trial that the violent death of the aforementioned individual was on account of his work as a journalist, as his ‘exposé’ journalism earned him the animosity of those who felt that they were adversely affected by his radio programs—to the point that there were many who filed criminal actions against him for alleged acts against moral integrity.” The case file also shows that, prior to his death, the journalist had been the victim of repeated threats on account of his work. 128. Notwithstanding the State’s argument that there is no judicial “certainty” with respect to the motive for the crime, the Commission observes that there is nothing in the case file that points to the existence of any other theory effectively considered by the national authorities during the investigations and criminal case pursued at the domestic level. What is clear and irrefutable in this case is that the journalist investigated issues of significant public interest to the local community and directly and consistently denounced head-on the authorities and businessmen of his city and the existence of a network that laundered the proceeds of drug trafficking in the area; that he was threatened, and that he was later brutally murdered. 129. As described below, in these types of cases the American Convention demands that positive measures be taken to ensure the investigation, prosecution, and, if appropriate, punishment of the perpetrators, in order to prevent impunity and its negative effects on freedom of expression. 130. The Inter-American Court has established that in order to determine whether the obligation to guarantee the rights of a murdered person has been fully met through a serious investigation of the events, the Court “must examine the different measures taken by the State after the bodies were found, as well as the domestic procedures to elucidate what occurred and to identify those responsible for the violations perpetrated against the victims.” In this respect, the Court has emphasized that “clarification of whether the State has violated its international obligations owing to the actions of its judicial bodies can lead the Court to examine the corresponding domestic proceedings. Hence, according to the circumstances of the case, the Court may have to examine the procedures that are followed in order to establish the grounds for judicial proceedings, particularly the investigative measures on which the opening and evolution of such proceedings depend.”138 131. Accordingly, it is incumbent upon the IACHR to determine whether the authorities acted with due diligence during the investigation and criminal proceedings conducted after the murder of journalist Nelson Carvajal Carvajal, and it will examine the alleged irregularities concerning: (a) the lack of protection, given the threats, intimidation, and pressures to which relatives and witnesses were subjected; (b) the lack of due diligence in the gathering of evidence; (c) lines of investigation and identification of perpetrators; (d) the undue delay and absence of substantial progress in the investigations; and (e) obstacles to the participation of the murdered journalist’s relatives in the proceedings. All of this will be examined in light of the international standards developed supra with respect to the general and specific obligations of States to investigate, prosecute, and, if appropriate, punish the perpetrators in cases involving the murder of journalists on account the exercise of their right to freedom of expression. a. Protection of the relatives of journalist Nelson Carvajal Carvajal and witnesses in the case from threats and acts of intimidation 132. The IACHR has indicated that the existence of an adequate institutional framework is crucial for the State to meet its obligation to investigate, prosecute, and punish crimes against journalists. To that 138 Cfr. I/A Court H.R., Case of Garibaldi v. Brazil. Preliminary Objections, Merits, Reparations, and Costs. Judgment of September 23, 2009. Series C No. 203, para. 120; I/A Court H.R., Case of Barrios Family v. Venezuela. Merits, Reparations and Costs. Judgment of November 24, 2011. Series C No. 237, para. 181.