81 293. As for the conduct of judicial authorities, the Commission has already indicated (see supra paras. 259-268) the delay in taking the various steps. Furthermore, the State’s delays in the investigation also had severe repercussions on the possibility of punishing those who were responsible for the crime. The Commission observes that, according to information available in the course of the investigation, persons who might have participated in the events have died; two of the alleged victims who were witnesses to some of the incidents of the case and who made their depositions are now disappeared persons; and the municipal ombudsman of Cocorná was killed, whereas the one from Carmen del Viboral has supposedly taken refuge abroad. 294. With regard to the fourth element, the Court has held that in determining the reasonableness of the time it should be considered the adverse effect of the length of proceedings in the legal status of the person involved in it and the interests at stake394. The Commission considers that the delay in a process where state officials are involved in accusations of serious human rights violations is an element that needs to be taken into account. In this regard, if the passage of time has a relevant impact on the legal status of the individual, it is necessary for the advancement of the procedure with greater diligence in order to ensure that the case is resolved swiftly and efficiently. 295. In short, the Commission deems that a delay of 17 years for justice to be administered exceeds what could be viewed as reasonable for the State to diligently carry out its investigative activities and constitutes a denial of justice to the detriment of the next of kin of the victims. 7.1.7. Conclusion 296. On the basis of all that was indicated, the Commission concludes that the domestic investigations and proceedings have not been effective remedies to guarantee access to justice, discover the truth about the events, investigate and punish those responsible, or provide redress for the consequences of the violations. Therefore, the IACHR deems that the State has violated Articles 8.1 and 25 of the American Convention, in connection with its duty to ensure respect as set forth in Article 1.1of the same instrument; as well as article I.b) of the Inter-American Convention on The Forced Disappearance of Persons, to the detriment of victims that have been disappeared395 and the next of kin of the victims of the case that are listed in the only annex of the instant report. 7.2. Other proceedings 297. As for military criminal justice, the Inter-American Court has already ruled that military criminal courts are not appropriate forums to hear, try and punish cases that involve the violations of human rights. In that regard the Court has already established that: 394 I/A Court H.R., Caso of Garibaldi v. Brasil. Preliminary Excepctions, Merits, Reparations and Costs. Judgment of September 23, 2009. Series C No. 203, paragraph 138; Case of Valle Jaramillo and others v. Colombia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 192, paragraph 155; Case of Kawas Fernández v. Honduras. Merits, Reparations and Costs. Judgment of April 3, 2009 Series C No. 196, paragraph 115. 395 Aníbal de Jesús Castaño Gallego; Óscar Hemel Zuluaga Marulanda; Juan Crisóstomo Cardona Quintero; Miguel Ancízar Cardona Quintero; María Irene Gallego Hernández; Juan Carlos Gallego Hernández; Jaime Alonso Mejía Quintero; Hernando de Jesús Castaño Castaño; Octavio de Jesús Gallego Hernández; Orlando de Jesús Muñoz Castaño; Leonidas Cardona Giraldo; and Andrés Gallego Castaño.

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