87. Both the Commission and the Inter-American Court have consistently held that, in general, the guarantees recognized in Article 8 of the American Convention are not confined to criminal proceedings, but apply also to other types of proceedings.54 88. Specifically, where punitive proceedings are concerned, both organs of the system have held that the guarantees enshrined in Article 8.2 of the American Convention apply analogously,55 as does the principle of legality and freedom from ex post facto laws established in Article 9 of the same treaty.56 The “due guarantees” established in Article 8.1 of the American Convention are also applicable in other proceedings in which rights or interests are addressed, including the right to sufficient justification for decisions. 57 The decision as to what constitute "due guarantees" in a particular proceeding for a determination on rights must take into account the nature of the proceeding and the legal interests in play.58 89. Based on the above, to determine which guarantees the State had the obligation to afford in a specific case, it is necessary to refer the nature of the proceeding in question. 90. This case involves an impeachment proceeding that culminated in the decision to dismiss the alleged victim from his post as judge of the Sixth Labor Tribunal of the Department of San Isidro and declare him ineligible to exercise judicial functions. The Commission also notes that, as is mentioned in the section on proven facts, the Impeachment Jury, had the authority under Article 42.b of the Law to determine whether the alleged victim had committed criminal offenses. In that regard, the Commission considers that it was a punitive proceeding that involved the punitive power of the State and, therefore, the applicable guarantees analogously included the ones applicable in criminal proceedings. Of particular relevance for the analysis in this case are the guarantees established in Articles 8.1, 8.2, and 9 of the American Convention. 91. In addition to the punitive nature of the proceedings, the Commission considers it appropriate to formulate a number of general considerations on the enhanced guarantees in proceedings for the dismissal of judges, as well as on the impeachment of judicial operators. 92. The principle of judicial independence is an inherent requirement of a democratic system and a fundamental prerequisite for the protection of human rights.59 It is enshrined as one of the fair-trial guarantees protected by Article 8(1) of the American Convention; moreover, that principle gives rise in turn to “strengthened”60 guarantees that states must provide to judges to ensure their independence.61 The organs 54IACHR, Report No. 65/11, Case 12.600, Merits, Hugo Quintana Coello et al. (Supreme Court of Justice) Ecuador, March 31, 2011, par. 102. 55 I/A Court H.R., Baena Ricardo et al. Case v. Panama. Merits, Reparations, and Costs, Judgment of February 2, 2001. Series C No. 72, pars. 126-127. See also: IACHR, Access to Justice as a Guarantee of Economic, Social, and Cultural Rights. A Review of the Standards Adopted by the Inter-American System of Human Rights. OEA/Ser.L/V/II.129, September 7, 2007, pars. 98-123; and Case No. 12.828, Report 112/12, Marcel Granier et al., Venezuela, Merits, November 9, 2012, par. 188. 56 I/A Court H.R., Baena Ricardo et al. Case v. Panama. Merits, Reparations, and Costs, Judgment of February 2, 2001. Series C No. 72, par. 106. 57 IACHR, Report No. 43/15, Case 12.632, Merits (Publication), Adriana Beatriz Gallo, Ana María Cariaga and Silvia Maluf de Christin, Argentina, July 28, 2015, par. 136; I/A Court H.R.Case of Barbani Duarte et al. v. Uruguay. Merits, Reparations and Costs. Judgment of October 13, 2011. Series C No. 234, par. 118; and Case of Claude-Reyes et al. v. Chile, Merits, Reparations, and Costs, Judgment of September 19, 2006. Series C No. 151, par. 118. 58 I/A Court H.R., Case of Barbani Duarte et al. v. Uruguay. Merits, Reparations and Costs. Judgment of October 13, 2011. Series C No. 234, pars 118-119. 59IACHR, Report on Merits 12.816, Report No. 103/13, November 5, 2013, par. 112. Citing United Nations, Human Rights Committee, General Comment No. 32, CCPR/C/GC/32, 23 August 2007, para. 19. In that same connection, see Habeas corpus in Emergency Situations (Arts. 27(2), 25(1) and 7(6) American Convention on Human Rights). Advisory Opinion OC-8/87 of January 30, 1987. Series A No. 8, par. 30. See also IACHR, Democracy and Human Rights in Venezuela, Ch. III, Independence and Separation of Public Powers, December 30, 2009, par. 80. 60I/A Court H.R., Case of Reverón Trujillo v. Venezuela, Preliminary Objection, Merits, Reparations and Costs. Judgment of June 30, 2009. Series C No. 197, par. 67; IACHR, Democracy and Human Rights in Venezuela, December 30, 2009, par. 185. Available at: http://www.cidh.org/countryrep/Venezuela2009eng/VE09.TOC.eng.htm; IACHR, Second Report on the Situation of Human Rights Defenders in the Americas, December 31, 2011, par. 359.