(viii) General comment No. 14 of the United Nations Committee on Economic, Social and Cultural Rights, on “The right to the highest attainable standard of health (Article 12)”;61 Article (ix) General comment No. 9 of the United Nations Committee on Economic, Social and Cultural Rights, on “The domestic application of the Covenant.” 62 (x) General comment No. 3 of the United Nations Committee on Economic, Social and Cultural Rights, on “The nature of States parties' obligations (paragraph 1 of Article 2 of the Covenant).” 63 30. Similarly, when the Judgment examines the violation of the right to judicial guarantees and to judicial protection established in Articles 8(1) and 25(1) of the American Convention, in relation to the obligations of respect and guarantee of Article 1(1) of this instrument, the Inter-American Court determined that there had been errors, delays and omissions in the criminal investigation proceedings, and that therefore “the State authorities did not act with due diligence or in keeping with the obligations to investigate and to ensure effective judicial protection within a reasonable time, in order to guarantee to Melba Suárez Peralta a reparation enabling her to have access to the medical treatment required by her health problems” 64 (underlining added). 31. I consider that, with all these precedents in the corpus juris with regard to protection of the right to health — in the sphere of the inter-American and the universal system — mentioned and used in the Judgment that prompts this separate opinion, even having recourse to very relevant decisions of the United Nations Committee on Economic, Social and Cultural Rights, as well as other recent international sources, such as the Social Charter of the Americas, adopted in June 2012 by the OAS General Assembly, the Inter-American Court could have approached this social rights Article autonomously, in relation to the obligation of guarantee referred t in 1(1) of the Pact of San José. 32. This is so, because, on the one hand, the interdependence and indivisibility of rights and the absence of a hierarchy among them is expressly recognized in the Judgment and, on the other hand, the OAS Charter and the American Declaration on the Rights and Duties of Man are used, even deriving the right to health from that instrument in relation to the provisions of Article 26 of the American Convention. 65 In addition, reference is made to Article 10 of the Protocol of San Salvador, which I consider would have provided an opportunity to make an evolutive and systematic interpretation of this precept and of Article 26 of the American Convention, in light of other treaty-based provisions, such as Article 29 of the Pact of San José and Articles 4 and 19(6) of the Protocol of San Salvador. obligations related to the right to health. Competences of Ministries or of Superindences to receive complaints from the health system users. Policies for training judges and lawyers on the right to health.” 61 Cf. footnotes 175, 182, 217, 220, 221 and 222 of the Judgment. 62 Cf. footnotes 175 and 179 of the Judgment. 63 Footnote 176 of the Judgment. 64 Para. 122 of the Judgment. 65 The reference is found in footnote 176 to para. 131 of the Judgment, from which the Inter-American Court considers that the right to health is derived. 12