9 of the American Convention and at Article 31(2)(a) of the its Rules of Procedure applies, since prima facie there was no legislation in the State that guaranteed due process of law to protect the rights that the petitioner argues were violated in respect of the alleged victims’ next-of-kin. 41. In addition, given that the criminal investigation was never carried out under laws that guaranteed due process, the Commission considers prima facie that there is unwarranted delay, thus the exception to the exhaustion of domestic remedies provided for at Article 46(2)(c) of the American Convention and Article 31(2)(c) of the Commission’s Rules of Procedure is also applicable. 42. It should be clarified that Article 46(2), given its nature and purpose, is a provision with autonomous content vis-à-vis the substantive provisions of the American Convention. Therefore, the determination of whether the exceptions to the prior exhaustion rule are applicable to the case in question should be made prior to and separate from the analysis of the merits, for it depends on a different standard of appreciation from that used to determine a possible violation of the American Convention.5 The foregoing also applies to Article 31(2) of the Commission’s Rules of Procedure. 2. Time period for submitting the petition 43. The American Convention establishes that for a petition to be admissible by the Commission it must be submitted within six months from the date on which the alleged victim was notified of the final decision. In the claim under analysis, the IACHR has established the application of one of the exceptions to the exhaustion of domestic remedies established at Article 46(2)(a) of the American Convention and Article 31(2)(a) of the Commission’s Rules of Procedure. In this respect, Article 32 of the Commission’s Rules of Procedure establishes that in the cases in which the exceptions to the prior exhaustion of domestic remedies apply, the petition should be submitted within a time which, in the view of the Commission, is reasonable. To that end, the Commission should consider the date on which the alleged violation of rights has taken place, and the circumstances of each case. 44. In the instant case, the petition was received on August 15, 2007. In addition, the alleged facts that are the subject of the claim are said to have begun on December 13, 1974, with respect to Luis Eduardo González González, on July 19, 1977, with respect to Oscar Tassino Asteazu, and occurred on April 21, 1974 with respect to Diana Maidanic, Laura Raggio Odizzio, and Silvia Reyes; and the criminal investigations were said to have been archived by the Judicial branch on December 19, 2006, with respect to the alleged forced disappearance of Luis Eduardo González González, and on February 16, 2007 with respect to the alleged extrajudicial executions of Diana Maidanic, Laura Raggio Odizzio, and Silvia Reyes, and the forced disappearance of Oscar Tassino Asteazu. 45. Considering that after more than 30 years the criminal investigations initiated had not clarified the circumstances of the alleged forced disappearances and extrajudicial executions, due allegedly to the non-existence of a legal framework to guarantee criminal due process, and considering that the effects of the alleged failure of the administration of justice are said to extend to the present day, the Commission considers that the petition was filed within a reasonable time, and that one should consider the admissibility requirement related to the time for submitting the matter to have been met in all cases. 3. 5 Duplication of procedures and international res judicata IACHR, Report No. 13/09, Petition 339-02, Admissibility, Vinicio Poblete Vilches, Chile, March 19, 2009, para. 54.