reasonable time. In that regard, a prolonged delay may constitute, in itself, a violation of the right to a fair trial,219 and that, therefore, it is for the State to explain and prove why it has required more time than would be reasonable to deliver a final judgment in a specific case.220 103. In that connection, reasonableness of time must be analyzed with regard to the total duration of the criminal process.221 Pursuant to Article 8 (1) of the American Convention, the Commission will consider, in light of the specific circumstances of the case, the following four elements: (i) the complexity of the case; (ii) the procedural activity of the interested party; (iii) the conduct of the judicial authorities; and (iv) the general effects on the legal situation of the person involved in the proceeding.222 104. As regards complexity, the State argued that “those events [only] came to the knowledge of the State 14 years after they took place,” which is not the case, given that, as was accredited, agents of the State not only committed the crimes with which this case is concerned, but actively participated in their concealment and in the persecution of the victims, among others, in order to prevent them from reporting the facts to judicial bodies. The Guatemalan Army and the Ministry of Defense are as much an integral part of the State as its judicial bodies are. The State cannot plead ignorance of the facts when the actions of its own organs impeded or obstructed the efforts of other State bodies responsible for the investigation and trial. In that connection, it should be underscored, once more, that it was incumbent upon the State, not the victims, to move the proceedings forward, as the State had the obligation to open an investigation into the facts ex officio as soon as they occurred. 105. While this is a complex case, as the Court has consistently held, even in highly complex cases courts must act with due diligence, since “the complexity of the matter under investigation in the domestic jurisdiction does not, in itself, justify the fact that criminal proceedings are still [so long] after the event.”223 Furthermore, the obligation to employ due diligence is particularly important in cases of gross human rights violations, in respect of which “all available means [must be used] to carry out all such steps and inquiries as are necessary to achieve the goal pursued ... [and] all necessary measures must be adopted in order to prevent the systematic patterns that led to the commission of serious human rights violations.” 224 Efforts to investigate promptly should be redoubled in cases of gross violations because “the passage of time has a directly proportionate relationship to the limitations to—and, in some cases, the impossibility of—obtaining evidence and/or testimony, making it difficult and even rendering ineffective or invalid, the probative measures taken in order to elucidate the facts investigated, identify the possible authors and participants, and determine possible criminal responsibilities.”225 106. As for the participation of interested parties, the Commission observes that the relatives, victims, and witnesses have actively contributed to the case by following up and advancing the investigation. 107. Summarizing, the Commission considers that the delay in the administration of domestic justice far exceeds what might be considered a reasonable period of time and therefore constitutes a denial of justice to the detriment of the victims’ relatives. I/A Court H.R., Moiwana Community Judgment, par. 160; I/A Court H.R., Case of Gómez Palomino v. Peru.Merits, Reparations and Costs, Judgment of November 22, 2005. Series C. No. 136. par. 85; I/A Court H.R., Case of García Asto and Ramírez Rojas v. Peru, Merits, Reparations and Costs, Judgment of November 25, 2005. Series C. No. 137, par. 166. 220 I/A Court H.R., Ricardo Canese Judgment, par. 142. 221 I/A Court H.R., Case of López Álvarez v. Honduras, Merits, Reparations and Costs, Judgment of February 1, 2006, Series C. No. 141. par. 129; I/A Court H.R., Case of Acosta Calderón v. Ecuador, Merits, Reparations and Costs, Judgment of June 24, 2005, Series C. No. 129. par. 104; and I/A Court H.R., Case of Tibi v. Ecuador, Preliminary Objections, Merits, Reparations, and Costs, Judgment of September 7, 2004, Series C. No. 114. par. 168. 222 I/A Court H.R., Massacre of Santo Domingo Judgment, par. 164. 223 I/A Court H.R., Valle Jaramillo Judgment, par. 156. See also I/A Court H.R., Case of Juan Humberto Sánchez v. Honduras. Preliminary Objection, Merits, Reparations and Costs, Judgment of June 7, 2003, Series C. No. 99. par. 130. 224 I/A Court H.R., Case of the Rochela Massacre v. Colombia, Merits, Reparations and Costs, Judgment of May 11, 2007, Series C. No. 163. par. 156. 225 I/A Court H.R., Case of Contreras et al. v. El Salvador, Merits, Reparations and Costs, Judgment of August 31, 2011, Series C. No. 232. par. 145. 219 27