48 however, he indicated that “he never learned" about the proceedings that the Ecuadorian Consulate was conducting on his behalf in December 2002. Furthermore, he mentioned that “he never knew how the deportation occurred” and that “he does not know the proceedings that were conducted to that end.”162 157. It is pertinent to recall that the right of a foreign detainee to request consular assistance from his country of nationality has been considered within the framework of the “minimum guarantees to offer foreigners the opportunity to adequately prepare their defense.”163 In this respect, the Court has emphasized several cases where the consul may assist the detainee in different acts of defense (supra para. 154), and its importance in guaranteeing the compliance with the right “to be assisted by a counsel” under Article 8(2)(d) of the Convention. In this way, “[n]on-observance or impairment of the detainee’s right to information is prejudicial to the judicial guarantees,”164 and may result in a violation thereof. 158. As to the effective access to consular communication, the Vienna Convention provides that the detainee has the right to: 1) freely communicate with consular officials; and 2) be visited by consular officials.165 According to this treaty, “consular officers shall have the right to visit a national of the sending State [and] to arrange for his legal representation.”166 That is to say, the recipient State must not hinder the acts of the consular official that provides legal services to the detainee. Furthermore, the detainee has the right to seek consular assistance, which binds the State, of which the detainee is a national, to protect the rights of its nationals in a foreign country by providing consular protection. The visits of consular officials should be made with a view to facilitating “the protection of interests” of the national detainee, especially those associated with “his or her defense before the courts.”167 In this respect, the right to the consular visit represents a condition to guarantee and enforce the rights to personal liberty, humane treatment [personal integrity], and defense. 159. The Court notes that even though Mr. Vélez Loor had proven communication with consular officials of Ecuador in the State of Panama,168 the administrative proceeding conducted between November 12 and December 6, 2002, which resulted in the resolution by which he was sentenced to imprisonment, did not give him the opportunity to avail himself of the right to defense, to a hearing, or to the safeguards of adversarial proceedings, let alone guaranteed that said right could be really exercised (supra para. 144). That is to say, even if Mr. Vélez Loor was visited at the penitentiary center by the consular officials at La Joyita Penitentiary Center after the 162 Statement rendered by Jesús Tranquilino Vélez Loor at the public hearing held before the InterAmerican Court on August 25, 2010. 163 The Right to Information on Consular Assistance in the Framework of the Guarantees of Due Process, supra note 145, para. 122; Case of Chaparro Álvarez and Lapo Íñiguez, supra note 99, para. 164, and Case of Bueno Alves, supra note 157, para. 116. 164 The Right to Information on Consular Assistance in the Framework of the Guarantees of Due Process, supra note 145, para. 129; Case of Acosta Calderón v. Ecuador. Merits, Reparations, and Costs. Judgment of June 24, 2005. Series C No. 129, paras. 125 and 126, and Case of Tibi, supra note 27, paras. 195 and 196. 165 Cf. Vienna Convention on Consular Relations, Articles 36.1.a and 36.1.b). 166 Vienna Convention on Consular Relations, Article 36.1.c). 167 Cf. The Right to Information on Consular Assistance in the Framework of the Guarantees of Due Process, supra note 145, para. 87; Case of Chaparro Álvarez and Lapo Íñiguez, supra note 99, para. 164 and Case of Bueno Alves, supra note 157, para. 116. 168 Cf. Note N° 4-2-105/2009, supra note 79, folio 2435 and 2436, and Note N° 3-8/09/2003 issued by the Embassy of Ecuador in Panama addressed to the Director of La Palma Penitentiary Center of February 26, 2003 (case file of the evidence, volume VIII, annex 53 of the response to the application, folio 3611).

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