that [Edgar Fernando García] was investigated because the State considered him to be an enemy.” 230 150. As part of the obligation to investigate forced disappearances, such as the one in this case, State authorities must determine procedurally the patterns of joint action and all those who, in different ways, participated in the said violations and their corresponding responsibilities. 231 It is not enough to know the material circumstances of the crime; rather, it is essential to analyze the information on the power structures that permitted, designed, masterminded and perpetrated it, as well as the individuals or groups who had interests in or would benefit from the crime (beneficiaries). Consequently, the crime cannot be analyzed in isolation, but rather in a context that provides the necessary elements to understand its operating structure. 232 151. The Court recognizes that, in the instant case, significant progress has been made in the investigation of the forced disappearance of Edgar Fernando García. Nevertheless, it emphasizes that, for more than 25 years, no measures were adopted to investigate his disappearance with due diligence. In addition, it would appear that all the logical lines of investigation arising from the abundant evidence provided by both the Historical Archive of the National Police and the Diario Militar are not being followed up on in the investigation that the Public Prosecution Service is conducting at this time. 4. Reasonable time 152. To ensure that the investigation is conducted in a genuine and impartial manner, and as an inherent legal obligation, the right of access to justice requires that the determination of the facts under investigation is made within reasonable time. 233 This Court has indicated that the “reasonable time” referred to in Article 8(1) of the Convention must be assessed in relation to the total duration of the proceedings undertaken until the final judgment is delivered. 234 The Court considers that, in principle, a prolonged delay, as occurred in this case, constitutes, in itself, a violation of judicial guarantees. 235 153. The Court has usually considered the following elements in order to determine the reasonableness of the time: (a) the complexity of the matter; (b) the procedural activity of the interested party; (c) the conduct of the judicial authorities, and (d) the effects on the legal situation of the person involved in the proceedings. However, in this case, the Court has verified that 25 years and 8 months have passed since the date on which the State accepted the Court’s jurisdiction 236 and more than seven years since the discovery of the 230 Cf. Judgment of the Eighth Crime, Drug-trafficking and Environmental Offenses Court of October 28, 2010, C-01069-1997-00001 (file of annexes to the State’s answering brief, single tome, annex I, folio 3972 and 3973). 231 Cf. Case of the La Rochela Massacre v. Colombia. Merits, reparations and costs. Judgment of May 11, 2007. Series C No. 163, para. 195, and Case of the Río Negro Massacres v. Guatemala, supra, para. 194. 232 Cf. Case of Manuel Cepeda Vargas v. Colombia, supra, para. 119, and Case of the Río Negro Massacres v. Guatemala, supra, para. 194. 233 Cf. Case of Hilaire, Constantine and Benjamín et al. v. Trinidad and Tobago. Merits, reparations and costs. Judgment of June 21, 2002. Series C No. 94, para. 14, and Case of Chitay Nech et al. v. Guatemala, supra, para. 196. 234 Cf. Case of Suárez Rosero v. Ecuador. Merits. Judgment of November 12, 1997. Series C No. 35, para. 71, and Case of the Río Negro Massacres v. Guatemala, supra, para. 229. 235 Cf. Case of Hilaire, Constantine and Benjamin et al. v. Trinidad and Tobago, supra, para. 145, and Case of the Río Negro Massacres v. Guatemala, supra, para. 229. 236 At the date of delivery of this Judgment, 28 years and 9 months have passed since the start of the forced disappearance of Edgar Fernando García. 54

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