applied to each particular situation, which are: (a) the complexity of the matter, (b) the conduct of the judicial authorities, and (c) the procedural activity of the interested party.144 161. The criminal proceeding against the accused lasted four years, three months, and one day. Taking into account the above elements of analysis, the Commission finds, in first place, that the victim in this case was a single individual whose identity was established from the outset, the facts were immediately known by the State, and the police officers present during the operation were identified on the very day of the events. Furthermore, the appropriate authorities had free access to the scene of the events and the opportunity to carry out all the relevant technical tests. In such circumstances, the Commission believes that the present case was not particularly complex. 162. As to the conduct of the judicial authorities, the Commission notes that from the initial stage of the proceedings the State had at its disposal the evidence to clarify what happened. It was precisely a lack of proper diligence in this initial stage that made it necessary subsequently to perform additional tests to clarify the circumstances of the events, such as the exhumation of the corpse, which further prolonged the investigation. In particular, much of the delay was caused by the nullity declaration issued by the First Police District Court, which temporarily halted the proceeding. In that regard, the State has failed to offer any explanation with respect to the position of the petitioners in relation to the inaction of the judicial authorities, evinced by the fact that it took nine months for a superior court to take up the case after the First Police District Court declared said nullity. 163. The Commission finds, then, that the proceeding dragged on for more than four years, was conducted and concluded by the authorities in a special jurisdiction that lacked the guarantees of independence and impartiality, and the conduct and omissions of the authorities themselves have obstructed clarification of the events in the ordinary courts to this day. 164. Finally, concerning the procedural activity of the interested party, the Commission notes that Mrs. PatriciaAlexandra Trujillo Esparza presented a private indictment on January 4, 1993. The record contains no evidence of any procedural steps on the part of the family of the alleged victim that would have impaired the progress of the investigation. Although there is information about the desistance of the private indictment, as the act in question was a publicly actionable matter, that aspect is irrelevant for the purposes of the analysis of reasonable time. The IACHR notes that Mrs. Patricia Alexandra Trujillo Esparza participated actively in the proceeding by providing her account of what happened. 165. In light of the foregoing considerations, the Commission concludes that the delay in the investigation of the case and the absence, even now, of an independent and impartial investigation of the circumstances in which Mr. Valencia Hinojosa died are unreasonable and were due to the omissions of the authorities in charge of the investigation and prosecution of the case, in violation of Article 8(1) of the Convention. B. Right to life 166. As was mentioned at the beginning of the analysis, there are two theories as to how Mr. Valencia Hinojosa died. As was concluded in the foregoing section, the criminal investigation, which was the means by which the State should have clarified what happened, violated the American Convention and did not allow the truth of what happened to come to light. 167. Thus faced with that impossibility, which stems from the state's own negligence and actions in breach of the Convention, and taking into account the arguments of the parties on the imputation or not of 144IACHR, Report on Merits No. 77/02, Waldemar Gerónimo Pinheiro and José Víctor dos Santos (Case 11.506), December 27, 2002, par. 76. See also I/A Court H.R., Case of López Álvarez v. Judgment of February 1, 2006. Series C No. 141, par. 132; Case of García Asto and Ramírez Rojas Judgment of November 25, 2005. Series C No. 137, par. 166; and Case of Acosta Calderón. Judgment of June 24, 2005. Series C No. 129, par. 105; UN Doc. CCPR/C/GC/32 of August 23, 2007, Human Rights Committee, General Comment No. 32, para. 35.