identification and ballistics expert evidence that was fundamental to the conviction and the lack of
reasoning to reject the defense evidence.
117. This Court considers it necessary to recall that the right of defense is a central component of
due process.163 In criminal proceedings, the right of defense is intended both to provide the accused
with the necessary tools to demonstrate his innocence, and to take an active role in a rigorous control
of the process in order to guarantee the validity and credibility of the evidence presented to
demonstrate the guilt of the person on trial.164
118. In principle, the duty of sufficient justification to which State authorities are subject represents
an instrumental right of individuals to judicial guarantees and to fully exercise their right of defense,
by imposing on them the obligation to externalize the reasons that justify their decisions.165 In this
way, the administration of justice allows persons whose human rights have been affected to know
the reasons that led the judges to decide in a certain way, so that they can have the opportunity to
refute the considerations that support the decision if they consider them to be unjust. Now, while
this duty of sufficient justification does not require a detailed response to every argument, it does
require that the decisions have a rational argumentation that takes into account the allegations and
the body of evidence that has made up the process.166
119. Criminal proceedings involving highly relevant sanctions, such as the deprivation of personal
liberty or, more importantly, capital punishment, require judges to carry out the most scrupulous
scrutiny at the time of their decisions, since otherwise they would cause irreversible harm to the
convicted persons.167 In this context, the principle of presumption of innocence is important as it
demands the judicial authority to adopt its sentencing decisions based on a clear and evident reason
regarding the criminal responsibility of the accused, obtained in a trial in which the formalities that
guarantee the possibility of defense and the guarantees of due process of law have been respected.
120. This Court has described the content that must be satisfied in accordance with the duty of
sufficient justification in relation to the presumption of innocence of the accused, holding that "[t]he
Court underscores the relevance of the statement of reasons, in order to guarantee the principle of
presumption of innocence, especially in a conviction, which must express the sufficiency of the
evidence against the accused to confirm the accusatory hypothesis; the observance of the rules of
sound judicial discretion in the assessment of the evidence, including those that could cast doubt on
criminal responsibility; and the final judgment that derives from this assessment. If applicable, it
must reflect the reasons why it was possible to obtain the conviction on the charge and criminal
responsibility, as well as the evaluation of the evidence to disprove any hypothesis of innocence, and
only then to confirm or refute the accusatory hypothesis. This would make it possible to rebut the
presumption of innocence and determine criminal responsibility beyond reasonable doubt. In the face
of doubt, the presumption of innocence and the principle of in dubio pro reo, operate as a decisive
criterion at the time of issuing the ruling".168
Case of Ruano Torres et al. v. El Salvador. Merits, Reparations and Costs. Judgment of October 5, 2015. Series C
No. 303, para. 153.
164
Case of Pollo Rivera et al. v. Peru. Merits, Reparations and Costs. Judgment of October 21, 2016. Series C No. 319,
para. 319.
165
Case of Chaparro Álvarez and Lapo Íñiguez v. Ecuador. Preliminary Objections, Merits, Reparations and Costs.
Judgment of November 21, 2007, para. 107.
166
Cf. Case of Escher et al. v. Brazil. Preliminary Objections, Merits, Reparations and Costs. Judgment of July 6, 2009.
Series C No. 200, para. 196.
167
Cf. Case of Fermín Ramírez v. Guatemala, supra, para. 85.
168
Case of Zegarra Marín v. Peru. Preliminary Objections, Merits, Reparations and Costs. Judgment of February 15,
2017, para. 147.
163
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