temporal jurisdiction, the Court will analyze the alleged violations that occurred after December 10, 1998, in light of the enhanced obligations to investigate and punish those responsible for acts of violence against human rights defenders, while also taking into consideration the demonstrated context of violence and impunity (supra paras. 44–51). Accordingly, the Court will proceed with its analysis of the merits in the following order: (b) the alleged violation of the rights to judicial guarantees and to judicial protection, as well as the right to the truth, and (b) the alleged violation of the right to personal integrity of the family of Gabriel Sales Pimenta. VIII-1 RIGHTS TO JUDICIAL GUARANTEES 135 AND JUDICIAL PROTECTION, 136 AS WELL AS THE RIGHT TO THE TRUTH, 137 IN CONJUNCTION WITH THE OBLIGATION TO RESPECT AND ENSURE RIGHTS 138 A. Arguments of the parties and of the Commission 72. With respect to due diligence, the Commission held that Gabriel Sales Pimenta’s murder was attributable to his work defending rural workers and that this was not taken into account by the authorities. It also concluded that this case is characterized by state omissions with respect to its obligation to investigate and punish those responsible for the murder. It noted in this respect that the reason “a guilty judgment was not issued against [C.O.S.]” was a lack of evidence, even though the authorities in charge of the investigation had not even put him before the two eyewitnesses to the crime for identification. Moreover, the Commission indicated that the authorities did not act with due diligence to ensure that M.C.N. and J.P.N. were present, to prevent them from fleeing, or to enforce the detention orders against them. It added that because the State had neither “duly clarified nor disputed” the strong circumstantial evidence that individuals connected to the investigation had been threatened, it held that “it was also responsible for violating the duty to investigate with due diligence, which necessarily involves ensuring the safety and protection of witnesses before, during, and after the investigation.” 73. With regard to the issue of a reasonable timeframe, the Commission noted that over 20 years had passed between the murder of Mr. Sales Pimenta on July 18, 1982, and the declaration of the expiration of the statute of limitations. It argued that that length of time is in itself unreasonable. It stated that “the elements of complexity, actions of officials, and actions of family members do not explain or justify the excessive delay.” It also indicated that there were delays at different stages, for example, the length of time until the pronúncia judgment was finally issued in August of 2000, as well as between the request of the Public Prosecutor's Office for termination of criminal liability for J.P.N. in November of 1999 and the decision granting it in August of 2000. 74. The representatives agreed with the Commission’s arguments regarding the alleged violations committed in the context of the criminal trial, and they argued that the State: (i) did not take the necessary steps to investigate the murder of Gabriel Sales Pimenta or the prior threats against him, and failed to take into account factors such as his work as a human rights defender and the context in which the murder and the investigation thereof occurred, during the trial of three of the four suspects; (ii) did not take steps to identify, prosecute, or punish those responsible for the murder of Mr. Sales Pimenta; (iii) did not act with due diligence to enforce the detention orders issued during the trial to keep the defendants from fleeing; (iv) caused unjustified delays in the trial proceedings, which they noted is especially problematic for the reasonable time requirement in the September 8, 1982 (evidence file, folios 2265–2267); and Hearing record of case No. 0007348-91.2007.814.0028, Court of Justice of the State of Pará, March 24, 2011 (evidence file, folios 2009–2010). 135 Article 8 of the American Convention. 136 Article 25 of the American Convention. 137 Articles 8, 13, and 25 of the American Convention. 138 Article 1(1) of the American Convention. 23