invalidated the said judgments, the Supreme Court of Justice was composed of justices who previously, in the corresponding procedural actions, had indicated that they were disqualified from hearing the actions filed by the presumed victims (supra para. 50).170 164. The Court considers that it is not incumbent on it to enter into a discussion on whether or not Resolution No. 2382 of the Supreme Court of Justice was valid, or with regard to any legal or procedural effects that this could have had with regard to Judgments Nos. 951 and 952. However, the conflicting rulings of the Constitutional Chamber and the Supreme Court allow this Court to reiterate the ineffectiveness of the procedural actions filed and, thus, the non-binding nature of the judicial decisions, reflected in the fact that they could not be enforced; all without ignoring that a context of significant interference in judicial independence existed. 165. Consequently, the Court concludes that the ineffectiveness of the judicial remedies filed by the presumed victims, in a context of failure to respect the guarantees against external pressures that protect the function of judges, resulted in a violation of the right to judicial protection pursuant to Article 25(2)(c), in relation to the judicial independence recognized in Article 8(1) and the obligations to respect and to ensure rights established in Article 1(1), all of the American Convention. B.2. The guarantee of a reasonable time in processing and deciding the judicial actions filed by the presumed victims 166. The Court has established that a prolonged delay in the proceedings may, in itself, constitute a violation of judicial guarantees. 171 In each specific case, the assessment of the reasonable time must be analyzed in relation to the total duration of the proceedings, from the first procedural act until the final judgment is handed down, including any appeals that may eventually be filed.172 167. Case law has considered that four elements should be analyzed to verify whether the guarantee of a reasonable time has been satisfied: (a) the complexity of the matter; 173 (b) the procedural activity of the interested party; 174 (c) the conduct of the judicial authorities,175 The representatives included in their arguments other facts related to the actions of the Legislature and the Supreme Court of Justice in the context of the delivery of Judgment No. 737 of September 2, 2019, and Resolution A.I.N. No. 1932 of October 11, 2019. However, these facts exceed the factual framework contained in the Merits Report and, therefore, will not be analyzed in this judgment. 171 Cf. Case of Hilaire, Constantine and Benjamin et al. v. Trinidad and Tobago, supra, para. 145, and Case of Moya Solís v. Peru, supra, para. 98. 172 Cf. Case of Suárez Rosero v. Ecuador. Merits. Judgment of November 12, 1997. Series C No. 35, para. 71, and Case of Moya Solís v. Peru, supra, para. 98. 173 In order to analyze the complexity of the matter, the Court has taken into account, among other criteria, the complexity of the evidence, the plurality of procedural subjects or the number of victims, the characteristics of the remedy contained in domestic law, and the context in which the violation occurred. Cf. Case of Genie Lacayo v. Nicaragua. Preliminary objections. Judgment of January 27, 1995. Series C No. 21, para. 78, and Case of Olivares Muñoz et al. v. Venezuela. Merits, reparations and costs. Judgment of November 10, 2020. Series C No. 415, para. 123. 174 Regarding the activity of the parties interested in obtaining justice, the Court has taken into consideration whether their procedural activity has contributed in any way to unduly prolonging the proceedings. Cf. Case of Cantos v. Argentina. Merits, reparations and costs. Judgment of November 28, 2002. Series C No. 97, para. 57, and Case of Olivares Muñoz et al. v. Venezuela, supra, para. 123. 175 The Court has understood that, to fully achieve the effectiveness of the judgment, the judicial authorities must act promptly and without delay because the principle of effective judicial protection requires that execution procedures be implemented without undue delays or obstructions in order to achieve it purpose rapidly, simply and fully. Cf. Case of Mejía Idrovo v. Ecuador, supra, para. 106, and Case of Olivares Muñoz et al. v. Venezuela, supra, para. 123. 170 42

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