14 and omissions constitute the State’s failure to fulfill its obligation to effectively and adequately investigate the death of Ramón Mauricio García Prieto within a reasonable time, as well as to investigate the threats of which his next of kin and their attorneys were victim. In this sense, the Commission observed that “although […] in general, the denial of justice is a continuing violation, […] the Commission has identified […] independent events which are related to the violation of Articles 8 and 25 of the Convention.” Likewise, it alleged that various “threats received by the García Prieto Giralt family and their attorneys, which occurred subsequent to June 6, 1995, are related to the violation of Articles 5, 8, and 25 of the [American] Convention.” 36. The common intervener concurred with the Commission’s allegations with respect to the State’s preliminary objection. In this regard, the common intervener indicated that it had only submitted acts and events which began subsequent to June 6, 1995 for the Court’s consideration, such as the various threats, intimidating acts, and surveillance against the García Prieto Giralt family, as well as the lack of an adequate and effective investigation. 37. The Court reiterates what it has established in other cases, in the sense that the clause in which the Court’s jurisdiction is recognized is essential for the effectiveness of the international mechanisms of protection. Nonetheless, this clause must be interpreted and applied in light of the special nature of human rights treaties and their collective implementation. 16 38. The Court, like every organ with jurisdictional attributes, has the inherent power to determine the reach of its own jurisdiction. The instruments deposited by the States which recognize the compulsory jurisdiction of the Court (Article 62(1) of the Convention) presuppose the Court’s power to resolve jurisdictional controversies involving States which appear before the Court.17 This Tribunal takes into account the principle of non-retroactivity established in Article 28 of the Vienna Convention on the Law of Treaties of 196918 when determining the reach of its own jurisdiction. 39. The Tribunal has already established that the declaration contained in El Salvador’s instrument of recognition of the jurisdiction of the Court contemplates a temporal limitation on the Court’s jurisdiction. The objective of this temporal limitation is to exclude events or acts which occurred prior to the date on which the 16 Cf. Case of Ivcher Bronstein v. Perú. Jursidction. Judgment of September 24, 1999. Series C No. 54, para. 37; Case of the Serrano Cruz Sisters. Preliminary Objections. Judgment of November 23, 2004. Series C No. 118, para. 69; and Case of Nogueira Carvalho et al. v. Brazil. Preliminary Objections and Merits. Judgment of November 28, 2006. Series C No. 161, para. 42. 17 Cf. Case of Ivcher Bronstein. Jurisdiction, supra note 16, para. 34; Case of the Serrano Cruz Sisters. Preliminary Objections, supra note 16, para. 74; Case of Almonacid Arellano et al. Preliminary Objections, Mertis, Reparations and Costs. Judgment of September 26, 2006. Series C No. 154, para. 45; and Case of the Yean and Bosico Girls v. Dominican Republic. Preliminary Objections, Mertis, Reparations and Costs. Judgment of September 8, 2005. Series C No. 130, para. 78. 18 This Article establishes that “[u]nless a different intention appears from the treaty or is otherwise established, its provisions do not bind a party in relation to any act or fact which took place or any situation which ceased to exist before the date of the entry into force of the treaty with respect to that party.” See Also, Cf. Case of the Serrano-Cruz Sisters. Preliminary Objections, supra note 16, para. 64; Case of the Yean and Bosico Girls, supra note 17, para. 78; and Case of Nogueira de Carvalho et al, supra note 16, para. 43.