client’s legal defense.194 The Court also notes that the reason why he was only granted one day was because the trial court assumed that the lawyer was already familiar with the case. However, this Court considers that this argument was insufficient because the situation of each defendant had its own particular characteristics and complexities, and this warranted granting the lawyer sufficient time to be able to analyze the case thoroughly and, on this basis, to design an adequate defense strategy.195 Therefore, in the instant case, the Court considers that the time granted was extremely limited, considering: the need to examine the case, the significance of the proceedings and the possible consequences, and the review of the body of evidence to which any defendant has a right. 196 156. Consequently, the Court concludes that the State violated Article 8(2)(c) of the Convention, in relation to Article 1(1) thereof, to the detriment of Hugo Humberto Ruiz Fuentes. b.2 Right to appeal the judgment that convicted Mr. Ruiz Fuentes 157. In its consistent case law, the Court has referred to the content and scope of Article 8(2)(h) of the Convention, as well as to the standards that must be observed to ensure the right to appeal the judgment before a higher judge or court. The Court has understood that this right consists in an essential and minimum guarantee that “must be respected within the framework of due process of law in order to permit an adverse judgment to be reviewed by a different and higher judge or court […].”197 Bearing in mind that the purpose of the judicial guarantees is to ensure that a defendant in judicial proceedings is not subject to arbitrary decisions, the Court has interpreted that the right to appeal a judgment cannot be effective if it is not guaranteed to anyone who has been sentenced and convicted,198 because the sentence is a manifestation of the exercise of the State’s punitive powers. 199 The Court has considered that the right to appeal the judgment is one of the minimum guarantees accorded to anyone subject to a criminal investigation and proceedings. 200 158. The Court has also indicated that Article 8(2)(h) of the Convention refers to an ordinary, accessible and effective remedy; that is, it should not require great complexity that would render this right illusory. It should be understood that, regardless of the appeal system or regime adopted by the States Parties, and of the name given to the means of contesting the judgment, in order to be effective, it must constitute an adequate means of ensuring the rectification of an erroneous conviction. This means that it must be able to analyze the factual, evidentiary and legal matters on which the contested judgment was based because, in jurisdictional activities, the factual determinations and the application of the law are interdependent, so that an erroneous determination of the facts entails a flawed or undue application of the law. Consequently, the reasons for the admissibility of the appeal should make it possible to exercise a wide-ranging control of the contested Cf. Record of hearing C-4-98. Statement made by Hugo Humberto Ruiz Fuentes during the oral and public trial hearings before the Sixth Sentencing Court for Drug-trafficking and Environmental Crimes on April 21, 1999 (evidence file, folios 1135 and 1136). 195 Cf., mutatis mutandis, Case of Castillo Petruzzi et al. v. Peru in which the lawyers only had access to the case file the day before the delivery of the first instance judgment, owing to which the Court concluded that the presence and actions of the defense counsel were a mere formality and that the victims did not have an adequate defense. Case of Castillo Petruzzi et al. v. Peru. Merits, reparations and costs. Judgment of May 30, 1999. Series C No. 52, para. 141. 196 Cf. Case of the “White Van” (Paniagua Morales et al.) v. Guatemala. Merits. Judgment of March 8, 1998. Series C No. 37, para. 152, and Case of Barreto Leiva v. Venezuela, supra, para. 54. 197 Cf. Case of Herrera Ulloa v. Costa Rica. Preliminary objections, merits, reparations and costs. Judgment of July 2, 2004. Series C No. 107, para. 158, and Case of Amrhein et al. v. Costa Rica. Preliminary objections, merits, reparations and costs. Judgment of April 25, 2018. Series C No. 354, para. 255. 198 Cf. Case of Mohamed v. Argentina. Preliminary objection, merits, reparations and costs. Judgment of November 23, 2012. Series C No. 255, paras. 92 and 93, and Case of Gorigoitía v. Argentina. Preliminary objections, merits, reparations and costs. Judgment of September 2, 2019. Series C No. 382, para. 47. 199 Cf. Case of Baena Ricardo et al. v. Panamá. Merits, reparations and costs. Judgment of February 2, 2001. Series C No. 72, para. 107, and Case of Gorigoitía v. Argentina, supra, para. 47. 200 Cf. Case of Zegarra Marín v. Peru. Preliminary objections, merits, reparations and costs. Judgment of February 15, 2017. Series C No. 331, para. 171, and Case of Gorigoitía v. Argentina, supra, para. 47. 194 38