of the judicial decision to effectively collect the compensation in the instant case is part of the proceedings297 and shall be taken into account to analyze the reasonable term. 152. Based on the foregoing, the period that will be analyzed in the instant case starts on December 18, 1990 and ends on March 12, 2003, in other words, approximately 12 years and three months. Having determined the duration of the proceedings, the Court will apply the reasonable term assessment, analyzing four elements that the case law has established to determine the reasonableness of the length of time of the proceeding: a) the complexity of the matter; b) the procedural activity of the interested party; c) the conduct of the judicial authorities,298 and d) adverse effect of the duration of proceedings on the judicial situation of the interested party.299 C.2) Complexity of the matter Arguments of the parties and of the Inter-American Commission 153. With respect to the first element, namely, the complexity of the matter, the Commission noted that the case “does not involve a high degree of complexity, inasmuch as it is a civil suit for damages, wherein the only thing to be determined was: i) “whether the damages occurred; ii) whether that act can be attributed to the State, and iii) once responsibility is ascribed, proceed to execute the judgment.” It added that “the purpose of the civil proceedings that were brought was to determine whether a State entity was responsible or not for damages done to one person.” 154. The representatives indicated that “the suit for damages was not very complex, since it was only necessary to determine that damages had occurred, and to establish whether those damages were attributable to the State.” In addition, “the evidence offered and produced was not complex either,” insofar as “it was only necessary to perform two medical assessments on Sebastián [Furlan] and receive the statements of witnesses to the facts.” 155. The State did not refer specifically to the issue of complexity of the matter in the instant case. Considerations of the Court 156. This Court has taken into account several criteria to determine the complexity of 297 In this regard, see ECHR, Case of Immobiliare Saffi v. Italy, (No. 22774/93), G.C. Judgment of 28 July 1999, para. 63. In this Case the European Court ruled on the reasonable term of judicial proceedings aimed at recovering ownership of a leased building. The company Immobiliare Saffi, owner of the building where the lessee refused to leave in spite of numerous attempts, claimed that the judicial agents were unable to enforce the order, and it only recovered ownership when the lessee passed away. In this case, the Court concluded that: “In any event, the Court recalls that the right to a court would be illusory if a Contracting State's domestic legal system allowed a final, binding judicial decision to remain inoperative to the detriment of one party. It would be inconceivable that Article 6 § 1 should describe in detail procedural guarantees afforded to litigants – proceedings that are fair, public and expeditious – without protecting the implementation of judicial decisions” and that the “[e]xecution of a judgment given by any court must therefore be regarded as an integral part of the “trial” for the purposes of Article 6.” ) 298 Cf. Case of Genie Lacayo v. Nicaragua. Merits, Reparations and Costs. Judgment of January 29, 1997. Series C No. 30, para. 77, and Case of Díaz Peña v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of June 26, 2012. Series C No. 244, para. 49. 299 Cf. Case of Valle Jaramillo et al. v. Colombia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 192, para. 155, and Case of Díaz Peña v. Venezuela, para. 49. 51

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