23 because of a delay of “ten years to conclude the criminal proceedings” and that there are still “arrest warrants pending for 11 persons, which translates into 22 years of impunity.”116 76. The State claimed that it had complied with Articles 8 and 25 of the Convention. It emphasized that “it guaranteed access to the courts […] and to an effective remedy […], which was shown by the convictions.” It considered that its “diligent action 117 [ …] concluded with the conviction of 14 members of the national security forces and with the arrest warrants that are still in force for 11 persons, since they are still fugitives from justice.” It added that “the alleged victims […] had participated in the case since its beginning.” It pointed out that although the proceedings began in the military jurisdiction, they were transferred to the ordinary jurisdiction. It recalled that the Inter-American Court is “not a court of fourth instance” and cannot examine supposed errors of law or of fact of the domestic courts. Finally, it claimed that the length of the proceedings should be judged by taking into consideration that the case was “complex” and because different “incidents presented themselves.” B. Considerations of the Court 77. Under the American Convention, State Parties are obligated to provide effective judicial remedies to victims of human rights violations (Article 25), which must be substantiated according to the rules of legal due process (Article 8(1), all within the general obligation on the part of those States to guarantee the free and full exercise of the rights recognized in the Convention to every person under their jurisdiction (Article 1(1).118 78. Based on the foregoing, the Court will examine the elements of the investigation involving criminal justice. B.1. General considerations 79. The importance of the obligation to conduct an investigation in order, where appropriate, to establish responsibilities and sanctions depends on the nature of the rights representative made those statements on March 9, 2018, indicating that the date on which two of the 12 persons could request their release, it then indicated an earlier date, January 5, 2018. 116 At the public hearing, the representative was requested to specify the omissions and shortcomings that it alluded to. It responded in its final written arguments by, in addition to repeating considerations already reviewed, pointing out that the “facts that show the absence of interest on the part of the authorities:” (a) the Minister of Defense […] faulted the Community for the massacre, claiming that the soldiers were tricked into entering the Community, and (b) a rumor started that there would be a coup d’état due to the generalized discontent of the Army after the destitution of the Commander of Military Base No. 21 and for having accepted the resignation of the Minister of Defense. 117 It underlined that “the principal guidelines of the UN Manual for the Effective Prevention and Investigation of Extrajudicial, Arbitrary and Summary Executions were not available at the time when the events of this case occurred. However, […] the State […] developed a number of actions and followed the logical line of investigation to comply with the purpose of the criminal proceedings.” 118 Cf. Case of Velásquez Rodríguez v. Honduras. Preliminary Objections. Judgment of June 26, 1987. Series C No. 1, para. 91 and Case V.R.P., V.P.C. et al. v. Nicaragua. Preliminary Objections, Merits, Reparations and Costs. Judgment of March 8, 2018. Series C No. 350, para. 150. As to Article 1 of the Convention, the relevant parts establish: “Obligation to Respect Rights 1. The States Parties to this Convention undertake to respect the rights and freedoms recognized herein and to ensure to all persons within their jurisdiction the free and full exercise of their rights and freedoms, without any discrimination for reasons of race, color, sex language religion, political or other opinion, national or social origin, economic status, birth, or any other social condition.”