22 argued that there was a possible violation of the right to defense due to the alleged incompatibility of the joint defense (supra paras. 29 and 42). 82. Regarding the content and scope of Articles 8(2)(c) and 8(2)(e) of the Convention, this Court has already noted, with respect to public defenders, “the fundamental importance of cost-free legal counsel services for promoting and protecting the right of access to justice for everyone, particularly those who are especially vulnerable.” The institution of the public defender, through the provision of cost-free public legal aid, undoubtedly serves to adequately compensate for the procedural inequality of those facing the punitive power of the State, who are in a particularly vulnerable situation by being deprived of liberty, and to guarantee their effective access to justice on equal terms.80 83. Nevertheless, the Court has considered that the appointment of a defense counsel for the sole purpose of complying with a procedural formality would be tantamount to not having technical legal representation; therefore, it is imperative that the defense counsel act diligently in order to protect the procedural guarantees of the accused and thereby prevent his rights from being violated,81 thereby breaking the bond of trust. Therefore, the institution of the public defender, as a mechanism through which the State guarantees the inalienable right of any individual accused of a crime to be assisted by defense counsel, must provide sufficient guarantees to ensure effective action, on equal terms with the prosecution. The Court has recognized that to accomplish this objective the State must adopt all appropriate measures 82 to ensure access to qualified and trained defense attorneys who can act with functional autonomy. 83 84. The right to defense includes an effective and prompt defense, conducted by qualified professionals, which safeguards the specific interests of the accused and is not merely intended to comply with a formality in order to legitimize the proceeding. Thus, any form of “apparent” defense would violate the American Convention. In this regard, “[t]he bond of trust must be protected in every way possible within the public defense systems and [therefore, there must be] expeditious and prompt mechanisms so that the accused can request that the standard of his defense be evaluated. Moreover, no public defender may subordinate the interests of the person he is defending to other social or institutional interests or to the preservation of ‘justice.’” 84 85. The legal issue for analysis here is whether the State’s provision of joint defense counsel for the alleged victim and his co-accused is compatible with the Convention, in particular with Mr. Martínez Coronado's right to defense. The Commission and the representatives argue that the joint public defense had a negative impact on the interests of Mr. Martínez. 86. As a starting point, the Court notes that Article 95 of the Code of Criminal Procedure states that: “[t]he defense of several accused individuals in the same proceedings by the same counsel is, in principle, inadmissible. The court with jurisdiction according to the stage of the proceedings, or the Public Prosecutor, can allow joint defense when there is clearly no incompatibility. When there is incompatibility, it can be corrected by providing the necessary public defenders, according to the procedures for assigning counsel (supra para. 29). Thus, according to that text, the joint defense Cf. mutatis mutandi, Case of Vélez Loor v. Panama. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 23, 2010. Series C No. 218, para. 132, and Case of Ruano Torres et al. v. El Salvador. Merits, Reparations, and Costs. Judgment of October 5, 2015. Series C No. 303, para. 156. 81 Cf. Case of Cabrera García and Montiel Flores v. Mexico. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 26, 2010. Series C No. 220, para. 155, and Case of Ruano Torres et al. v. El Salvador, supra, para. 157. 82 Cf. Case of Chaparro Álvarez and Lapo Íñiguez v. Ecuador. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 21, 2007. Series C No. 170, para. 159, and Case of Ruano Torres et al. v. El Salvador, supra, para. 157. 83 Cf. Case of Ruano Torres et al. v. El Salvador, supra, para. 157. 84 Cf. Case of Ruano Torres et al. v. El Salvador, supra, para. 158. 80