In this sense, the Commission reiterates that the judicial authorities dismissed charges against the alleged intellectual authors of Mr. Palma´s kidnapping and murder, based on the fact that some of his family members had dropped charges and not on elements of conviction, in spite of the fact that the case involved crimes that are prosecutable de oficio, as the IX Criminal Prosecutor of Manabí pointed out in his written statement of May 12, 2000. 131. The Commission observes that, in relation to the material claim of this case, it will now examine whether the State fulfilled its duty to effectively investigate in a reasonable time period the material and intellectual authorship of the murder of Mr. Palma. 132. The Commission recalls that Article 8.1 of the Convention establishes that one of the elements of due process is that cases submitted to the courts must be ruled on by a competent judge within a reasonable time. In this sense, a prolonged delay can in and of itself come to constitute a violation of the right to a fair trial.120 The reasonableness of the time period must be evaluated in relationship to the total length of the criminal procedure.121. 133. Therefore, according to the terms of Article 8.1 of the Convention, and in light of the concrete circumstances of this case, the Commission will keep in mind the three elements that it has taken into account in its ongoing jurisprudence: a) the complexity of the matter, b) the conduct of judicial authorities, and c) the procedural activity of the interested party.122 134. With regard to the first, the Commission considers that the case was not a complex one, since the pick-up truck in which Mr. Palma was kidnapped was parked hours before the kidnapping on a public road and numerous people saw the people inside of it, as recorded by the Police Report from May 23, 1997. Furthermore, the dead body of Mr. Palma appeared on May 26, 1997. 135. Secondly, the Commission notes that in this case, the actions of the authorities have been deficient and without due diligence. In this regard, the IACHR notes that it concluded previously that Ecuador did not carry out the necessary procedures to investigate the events. In addition, the Commission would like to highlight that it has not received any information about any significant activity that took place between May 23, 1997—the date in which the O.I.D. sent its preliminary report of its investigations to the Eleventh Criminal Court Judge of Manabí—and February 26, 2000, the date in which another police report was sent to the same judge with the statement of Mr. Ordóñez in which he admitted having participated in Mr. Palma’s kidnapping. Furthermore, the Commission notes that in spite of the fact that a guilty verdict was issued against the direct perpetrators of Mr. Palma’s kidnapping and murder on March 19, 2001, that is to say four years after the crime was committed, the intellectual authors of the murder are still in impunity. 120 Inter-American Court. Case of García Asto and Ramírez Rojas Vs. Peru. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 25, 2005. Ser. C. No. 137, para. 166; Inter-American Court. Case of Gómez Palomino Vs. Peru. Merits, Reparations, and Costs. Judgment of November 22, 2005. Ser. C., No. 136, para. 85; Case of The Moiwana Community. Judgment of June 15, 2005, Ser. C. No. 124, para. 160. 121 Inter-American Court. Case of López Álvarez Vs. Honduras. Merits, Reparations, and Costs. Judgment of February 1, 2006. Ser. C., No. 141, para. 129; Inter-American Court. Case of Acosta Calderón Vs. Ecuador. Merits, Reparations, and Costs. Judgment of June 24, 2005. Ser. C. No. 129, para. 104; and Inter-American Court. Case of Tibi Vs. Ecuador. Preliminary Objections, Merits, Reparations, and Costs. Judgment of September 7, 2004. Ser. C. No. 114, para. 168. 122 IACHR, Report on Merits No. 77/02, Waldemar Gerónimo Pinheiro and José Víctor dos Santos (Case 11.506), December 27, 2002, para. 76. See also Inter-American Court, Case of López Álvarez, para. 132; Case of García Asto and Ramírez Rojas, para. 166; and Case of Acosta Calderón, para. 105; UN Doc. CCPR/C/GC/32 of August 23, 2007, Human Rights Committee, General Observation Nº 32, para. 35.