137. Consequently, given that the court took into account evidence obtained under coercion and torture when it issued the conviction on March 13, 2000, it is clear that said conviction was based on unlawful evidence obtained in an irregular manner, which is not admissible.119 138. In this regard, Article 10 of the Inter-American Convention to Prevent and Punish Torture (IACPPT) states that “[n]o statement that is verified as having been obtained through torture shall be admissible as evidence in a legal proceeding, except in a legal action taken against a person or persons accused of having elicited it through acts of torture, and only as evidence that the accused obtained such statement by such means.” 139. Accordingly, the Court concludes that in the conviction handed down against Mr. Grijalva Bueno in the military criminal proceedings, the judge considered unlawful evidence obtained under torture and coercion in violation of due process, and in violation of the essential judicial guarantees related to the right of defense, presumption of innocence, procedural equality and a fair trial, in breach of Articles 8(1) and 8(2) of the American Convention, in relation to Article 1(1) thereof, to the detriment of Mr. Vicente Aníbal Grijalva Bueno. Consequently, this Court considers that the military criminal proceeding against the victim was an arbitrary process, absolutely contrary to the Convention. A.2.4. Reasonable time 140. The Court has indicated that the right of access to justice entails an effective investigation of the facts and the determination of the corresponding criminal responsibilities, if applicable, within a reasonable time, since a prolonged delay may, in itself, constitute a violation of judicial guarantees.120 141. Although it is true that in order to analyze the reasonable time of an investigation or a proceeding the Court has indicated, in general terms, the need to consider the total duration of the process, from the first procedural act until the final judgment is handed down,121 in certain situations a specific assessment of the different stages may be pertinent.122 This Court has considered four elements to determine whether the In that regard, the European Court of Human Rights has reiterated that “It is not, therefore, the role of the Court to determine, as a matter of principle, whether particular types of evidence – for example, evidence obtained unlawfully in terms of domestic law – may be admissible. The question which must be answered is whether the proceedings as a whole, including the way in which the evidence was obtained, were fair. In determining whether the proceedings as a whole were fair, regard must also be had as to whether the rights of the defense have been respected and, in particular, whether the applicant was given an opportunity to challenge the authenticity of the evidence and to oppose its use. In addition, the quality of the evidence must be taken into consideration, as must the circumstances in which it was obtained and whether these circumstances cast doubts on its reliability or accuracy. While no problem of fairness necessarily arises where the evidence obtained was unsupported by other material, it may be noted that where the evidence is very strong and there is no risk of its being unreliable, the need for supporting evidence is correspondingly weaker.” Cf. ECHR, Case of Gäfgen v. Germany. No. 22978/05. Judgment of June 1, 2010, para. 163 and 164; Case of Khan v. United Kingdom. No. 35394/97. Judgment of May 12, 2000, para. 34 and 35, and Case of Allan v. United Kingdom. No. 48539/99. Judgment of November 5, 2002, para. 42 and 43. 120 Cf. Case of Hilaire, Constantine and Benjamin et al. v. Trinidad and Tobago. Merits, reparations and costs. Judgment of June 21, 2002. Series C No. 94, para. 145, and Case of Guzmán Albarracín et al. v. Ecuador. Merits, reparations and costs. Judgment of June 24, 2020. Series C No. 405, para. 180. 121 Cf. Case of Suárez Rosero v. Ecuador. Merits. Judgment of November 12, 1997. Series C No. 35, para. 71, and Case of Guzmán Albarracín et al, v. Ecuador. Merits, reparations and costs, supra, para. 181. 122 Cf. Case of the Displaced Afrodescendant Communities of the Cacarica River Basin (Operation Genesis) v. Colombia. Preliminary objections, merits, reparations and costs. Judgment of November 20, 2013. 119 36