had considered was the illegality of the origin of some appointments, and the legality of others.” Therefore, the State concluded that “no consistent elements existed to analyze a violation of Article 24 of the American Convention on Human Rights.” B. Considerations of the Court 165. In this section, first, the Court considers it opportune to ratify the fundamental criteria contained in the case of the Constitutional Court v. Peru. Second, it will analyze the possible effects on the judicial guarantees of the presumed victims, in both their removal from office, and in the impeachment proceedings that were held. Third, the Court will refer to the main standards relating to the principle of judicial independence. Fourth, it will explain the particularities of the institutional aspect of judicial independence in the circumstances of this case. 1. The Inter-American Court’s case law on judicial guarantees in impeachment proceedings 166. The Court has ruled on judicial guarantees in relation to the procedure for the removal of judges of a Constitutional Court in the context of an impeachment proceeding held by Congress in the case of the Constitutional Court v. Peru. The Court ratifies the following criteria mentioned in that case:192 68. Respect for human rights constitutes a limit to a State’s activity, and this is true for any organ or official in a situation of power, due to its official nature, with regard to other persons. Consequently, any form of exercising public power that violates the rights recognized in the Convention is unlawful. This is even more important when the State exercises its power to sanction, because this not only presumes that the authorities act with total respect for the legal system, but it also involves granting the minimum guarantees of due process to all persons who are subject to its jurisdiction, as established in the Convention. 69. Although Article 8 of the American Convention is entitled “Judicial Guarantees” [in the Spanish version - “Right to a Fair Trial” in the English version], its application is not strictly limited to judicial remedies, “but rather the procedural requirements that should be observed in order to be able to speak of effective and appropriate judicial guarantees” so that a person may defend himself adequately in the face of any kind of act of the State that affects his rights. 70. The Court has already established that, although this article does not establish minimum guarantees in matters relating to the determination of rights and obligations of a civil, labor, fiscal or any other nature, the full range of minimum guarantees stipulated in the second paragraph of this article are also applicable in those areas and, therefore, in this type of matter, the individual also has the overall right to the due process applicable in criminal matters. 71. Although the jurisdictional function belongs, in particular, to the Judiciary under the separation of powers that exists in the rule of law, other public organs or authorities may exercise functions of the same type. In other words, when the Convention refers to the right of everyone to be heard by a competent judge or court to “determine his rights,” this expression refers to any public authority, whether administrative, legislative or judicial, which, through its decisions determines individual rights and obligations. For that reason, this Court considers that any State organ that exercises functions of a materially jurisdictional nature has the obligation to adopt decisions that are in consonance with the guarantees of due legal process in the terms of Article 8 of the American Convention. […] 75. This Court considers that, under the rule of law, the independence of all judges and, in particular, that of constitutional judges, must be guaranteed owing to the nature of the matters submitted to their consideration. As the European Court has indicated, the independence of any 192 Cf. Case of the Constitutional Court v. Peru. Merits, reparations and costs. Judgment of January 31, 2001. Series C No. 71, paras. 68 to 71, 75 and 77. 48