51. As for the duration of Mr. Carranza's pretrial detention, the Commission notes that it lasted a little over four years: November 1994 to December 1998. The Commission notes that at no point during that time was there any periodic review to determine the ongoing propriety of the pretrial detention, despite the fact that Mr. Carranza requested his release. The foregoing is consistent with the above-cited provision of the Code of Criminal Procedure, whose logical consequence is that so long as the indicia of responsibility remain, pretrial detention is justified without any review of its duration in the light of the conventionally accepted needs. The Commission considers therefore, that the period of more than four years exceeded any criteria of reasonableness. 52. Consequently, from the moment that it began and throughout the more than four years that it lasted, that pretrial detention was arbitrary and, based on the above-cited standards, was a punitive rather than a precautionary measure, in violation both of the right to personal liberty and of the right to be presumed innocent. Therefore, the Commission concludes that the State of Ecuador is responsible for the violation of Articles 7(1), 7(3), 7(5), and 8(2) of the American Convention, taken in conjunction with the obligations established in Articles 1(1) and 2 of that instrument, to the detriment of Ramón Rosendo Carranza Alarcón. C. The right to a trial within a reasonable time 53. Article 8(1) of the American Convention provides: Every person has the right to a hearing, with due guarantees and within a reasonable time, by a competent, independent, and impartial tribunal, previously established by law, in the substantiation of any accusation of a criminal nature made against him or for the determination of his rights and obligations of a civil, labor, fiscal, or any other nature. 54. One of the elements of a fair trial is that tribunals reach a decision on cases submitted for their consideration within a reasonable time. The fulfillment of that guarantee implies not only that the remedies were decided in accordance with the rules of due process, but also that they were effective and offered due judicial protection from possible violations of human rights. 55. The Commission recalls that the elements that the organs of the inter-American system have considered in determining a reasonable time in the circumstances of each case are (i) the complexity of the matter; (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.52 The Inter-American Court has found that a prolonged delay may constitute, in itself, a violation of the right to a fair trial,53 and that, therefore, it is for the State to explain and prove why it has required more time than would be reasonable to deliver final judgment in a specific case.54 56. The proceedings in this case began with the order to institute proceedings issued on August 17, 1993, and concluded on December 15, 1998, with the final judgment that convicted Mr. Carranza, against which he did not lodge any appeal. Therefore, in all, the proceeding lasted five years and four months. 57. As to the complexity of the matter, the Commission notes that the case concerned a solitary victim and two accused. Based on the information available, there is nothing to suggest that the investigation 52IACHR, Report No. 111/10, Case 12.539, Merits, Sebastián Claus Furlan and family, Argentina, October 21, 2010, par. 100. I/A Court H.R., Case of the Massacre of Santo Domingo v. Colombia, Preliminary Objections, Merits and Reparations, Judgment of November 30, 2012, Series C No. 259, par. 164. 53 I/A Court H.R., Case of García Asto and Ramírez Rojas v. Peru, Judgment of November 25, 2005, Series C No. 137, par. 166; Case of Gómez Palomino v. Peru, Judgment of November 22, 2005, Series C No. 136, par. 85; Case of the Moiwana Community v. Suriname, Judgment of June 15, 2005, Series C No. 124, par. 160. 54 I/A Court H.R., Case of Ricardo Canese v. Paraguay, Judgment of August 31, 2004, Series C No. 111, par. 142. 10