41. The Commission will now consider whether the State violated the rights recognized in Articles 8(1),63 8(2),64 9,65 23(1)(c),66 and 25(1)67 of the Convention, taking into account the implications deriving from the principle of judicial independence and its protection under the American Convention. 1. The Principle of Judicial Independence 42. The principle of judicial independence is an inherent requirement of a democratic system and a fundamental prerequisite for the protection of human rights.68 It is enshrined as one of the fair-trial guarantees protected by Article 8(1) of the American Convention; moreover, that principle gives rise in turn to “strengthened”69 guarantees that states must provide to judges to ensure their independence.70 The organs of the Inter-American system have interpreted the principle of judicial independence as incorporating the following guarantees: an appropriate selection process, guaranteed tenure and the guarantee against external pressures.71 Specifically insofar as is relevant to this case, with respect to the guarantee of tenure, the Court has established that it “results in the subjective right of judges to be dismissed exclusively for the reasons permitted, either by a proceeding that complies with judicial guarantees or because their mandate has 63Article 8 (1) of the Convention provides: “Every person has the right to a hearing, with due guarantees and within a reasonable time, by a competent, independent, and impartial tribunal, previously established by law, in the substantiation of any accusation of a criminal nature made against him or for the determination of his rights and obligations of a civil, labor, fiscal, or any other nature.” 64Article 8 (2) of the Convention provides: “Every person accused of a criminal offense has the right to be presumed innocent so long as his guilt has not been proven according to law. During the proceedings, every person is entitled, with full equality, to the following minimum guarantees: [...] b. prior notification in detail to the accused of the charges against him; c. adequate time and means for the preparation of his defense; [...] h. the right to appeal the judgment to a higher court.” 65Article 9 of the American Convention provides: “No one shall be convicted of any act or omission that did not constitute a criminal offense, under the applicable law, at the time it was committed. A heavier penalty shall not be imposed than the one that was applicable at the time the criminal offense was committed. If subsequent to the commission of the offense the law provides for the imposition of a lighter punishment, the guilty person shall benefit therefrom.” 66Article 23(1)(c) provides: “Every citizen shall enjoy the following rights and opportunities: {...} c. to have access, under general conditions of equality, to the public service of his country.” 67Article 25(1) of the American Convention provides: “Everyone has the right to simple and prompt recourse, or any other effective recourse, to a competent court or tribunal for protection against acts that violate his fundamental rights recognized by the constitution or laws of the state concerned or by this Convention, even though such violation may have been committed by persons acting in the course of their official duties.” 68IACHR, Report on Merits 12.816, Report No. 103/13, November 5, 2013, par. 112. See United Nations, Human Rights Committee, General Comment No. 32, CCPR/C/GC/32, 23 August 2007, para. 19. In that same connection, see Habeas corpus in Emergency Situations (Arts. 27(2), 25(1) and 7(6) American Convention on Human Rights). Advisory Opinion OC-8/87 of January 30, 1987. Series A No. 8, par. 30. See also IACHR, Democracy and Human Rights in Venezuela, Ch. III, Independence and Separation of Public Powers, December 30, 2009, par. 80. 69I/A Court H.R., Case of Reverón Trujillo v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of June 30, 2009. Series C No. 197, para. 67; IACHR, Democracy and Human Rights in Venezuela, December 30, 2009, par. 185. Available at: http://www.cidh.org/countryrep/Venezuela2009eng/VE09.TOC.eng.htm; IACHR, Second Report on the Situation of Human Rights Defenders in the Americas, December 31, 2011, par. 359. 70Thus, for example, the Inter-American Court has held that the obligations of the State with respect to persons subject to judicial proceedings in the courts give rise, in turn, to “rights for judges,” which, according to the Court, include “the guarantee of not being subject to removal at will signifies that, in the case of judges, the disciplinary and punishment procedures must necessarily respect the guarantees of due process, and those subject to such procedures must be provided, among other matters, with an effective remedy.” I/A Court H.R., Case of Apitz Barbera et al. (“First Court of Administrative Disputes”) v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of August 5, 2008. Series C No. 182, par. 147. 71IACHR, Guarantees for the Independence of Justice Operators: Towards Strengthening Access to Justice and the Rule of Law in the Americas, December 5, 2013, pars. 56, 109 and 184, I/A Court H.R., Case of López Lone et al. v. Honduras. Preliminary Objection, Merits, Reparations and Costs. Judgment of October 5, 2015. Series C No. 302, par. 191. 11