63 324. With specific reference to the General Amnesty Law for Consolidation of the Peace, the Commission concluded in the Lucio Parada Cea case that “in approving and enforcing the General Amnesty Law, the Salvadoran State violated the right to judicial guarantees enshrined in Article 8(1) of the Convention, to the detriment of the surviving victims of torture and of the relatives of Lucio Parada and Héctor Miranda Marroquín, who were prevented from obtaining redress in the civil courts; all of this in 332 relation to Article 1(1) of the Convention” . It also found that El Salvador had “violated the right to judicial protection enshrined in Article 25 of the Convention, to the detriment of the surviving victims and those with legal claims on behalf of Lucio Parada and Héctor Miranda Marroquín; all of this in relation to Article 333 1(1) of the Convention.” 325. Subsequently, in the Ignacio Ellacuría S.J et al. case, the Commission concluded that: the amnesty decree provides that all persons who have been convicted must be released immediately, and that those against whom proceedings are underway, or who were in any way involved in serious violations of human rights, may not be investigated, prosecuted or punished, nor sued in the civil courts, all of which surrounds these grave human rights violations with impunity. Consequently, that law legally removes the right to justice established by Articles 1(1), 8(1) and 25 of the American Convention, since it makes impossible any effective investigation of human rights violations, or the prosecution and punishment of all those persons involved and the reparation of damages caused. Therefore (...) it disregards the legitimate rights of the victims’ next-of-kin to 334 reparation. Such a measure will do nothing to further reconciliation. 326. In the same case, the Commission also concluded that, in approving the General Amnesty Law for Consolidation of the Peace, El Salvador violated article 2 of the American Convention, 335 in concordance with article 1.1 thereof. 327. The Commission made a similar finding in the case of Monsignor Oscar Arnulfo Romero: the application of the General Amnesty Law of 1993 is incompatible with El Salvador’s obligations under the Convention, as it renders ineffective the right to judicial guarantees and judicial protection established at Articles 8(1) and 25 of the American Convention, as well as the general obligation assumed by the State to respect and guarantee the rights established in the Convention. Accordingly, the IACHR concludes that the State has violated Articles 2, 8, and 25 of the American 336 Convention, in conjunction with Article 1(1) of the Convention. 328. On the basis of this statement, in the Monsignor Oscar Arnulfo Romero case, the Commission recommended that the State of El Salvador “adapt its internal legislation to the American 337 Convention with a view to annulling the General Amnesty Law.” 329. It may be noted that in all the cases relating to El Salvador, the Inter-American Commission has recognized the great importance of the findings of the Truth Commission. Nevertheless, the Commission has also stressed that “in establishing the facts related to the more serious violations and in promoting national reconciliation, the functions [the Truth Commission] carried out can not be considered to be an appropriate substitute for the judicial process. Neither does it replace the State’s obligation to investigate the violations which were committed within the scope of its jurisdiction, as well as 332 IACHR. Report No. 1/99. Case 10.480. Lucio Parada Cea, Héctor Joaquín Miranda Marroquín, Fausto García Funes, Andrés Hernández Carpio, José Catalino Meléndez and Carlos Antonio Martínez Romero. 27 January 1999. Para. 123 333 Ibid., para 129. 334 IACHR. Report No. 136/99. Case. 10.488. Ignacio Ellacuría, S.J; Segundo Montes, S.J.; Armando López, S.J; Ignacio Martín Baró, S.J; Joaquín López y López, S.J; Juan Ramón Moreno, S.J; Julia Elba Ramos, S.J; and Cecilia Mariceth Ramos. El Salvador. 22 December 1999. Para. 215. 335 Ibid., para 217. 336 IACHR. Report No. 37/00. Case 11.481. Monseñor Oscar Arnulfo Romero y Galdámez. El Salvador. 13 April 2000. Para. 141. 337 Ibid., para 159.