human rights of the victims in this case, allowed for “conventionality control.”76 One was an appeal and the other was related to criminal matters (supra paras. 4 and 51). These judgments turned out to be particularly relevant for “ending the dispute” and reaching a friendly settlement agreement. In this regard, it was confirmed that “[w]ith [the criminal judgment of April 18, 2013] the Third Recommendation of the Report on Merits was fulfilled.”77 The Court emphasizes that the aforementioned judgments invoke the standards contained in the Convention and international standards contained in the Court’s jurisprudence regarding judicial guarantees in criminal proceedings, particularly with regard to the right to a defense, to the evidence upon which a judge may base his judgment, to the absolute exclusion of evidence obtained through torture or cruel and inhuman treatment, to the invalidity of a confession obtained under any type of coercion and the elements that constitute an act of torture.78 60. The amparo ruling of March 25, 2013 (supra para. 51) included some observations about the “principle of immediacy” in criminal proceedings and its connection with the guarantees of due process.79 Moreover, it specified that “any preliminary statements from anyone arrested in flagrante and brought before a judicial authority, will be vitiated and considered unlawful when the suspect or his legal representative has not been permitted to have a prior interview in private before making a preliminary statement.” Similarly, upon ruling on the inadequate assessment of the evidence and its unconstitutionality, it affirmed that “no procedure resulting from a stage at which no judge is present - i.e. the preliminary inquiry - can be taken in the proceedings as an action on the part of an authority which, presuming good faith, does not bear adversarial questioning, since the Public Prosecutor acts as a party in the process and the results of its inquiry should be submitted to scrutiny in the trial. In other words, the Public Prosecutor is simply another party, whose information is as much subject to rebuttal as that of the defendant.”80 Furthermore, it considered that in this case, one may “infer the possibility of the alleged commission of acts of torture to the detriment” of Messrs. García Cruz and Sánchez 76 In its consistent case law, the Court has established that it is aware that domestic authorities are subject to the rule of law and, therefore, are obligated to apply the current provisions of domestic law. When a State is Party to an international treaty such as the American Convention, all its organs, including its judges, are also subject to it. This requires the State to ensure that the effects of the Convention’s provisions are not undermined by the application of standards that are contrary to its object and purpose and that lack legal effects from the outset. Accordingly, this Court has established that all state authorities have an obligation to apply a “conventionality control” between domestic standards and the Convention, each within their respective spheres of competence and according to the relevant procedural rules. This refers to the analysis made by each State body and official (particularly judges and other judicial officials) regarding the compatibility of national standards and practices with the American Convention. In their decisions and specific actions, these bodies and officials must comply with the general obligation to guarantee the rights and liberties protected by the Convention, ensuring that they do not apply domestic legal standards which violate the treaty, and that they correctly apply this treaty and the case law developed by the Court. Cf. inter alia: Case of Almonacid Arellano et al. v. Chile. Preliminary Objections, Merits, Reparations and Costs. Judgment of September 26, 2006. Series C No. 124; Case of La Cantuta v. Peru. Merits, Reparations and Costs. Judgment of November 29, 2006. Series C No. 162, para. 173; Case of Gomes Lund et al. ("Guerilla of Araguaia") v. Brazil. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 24, 2010. Series C No. 219, para. 176; Case of Cabrera García and Montiel Flores v. Mexico, supra note 70, para. 225; Case of Gelman v. Uruguay. Merits and Reparations. Judgment of February 24, 2011. Series C No. 221, para. 193; Case of Furlan and Family v. Argentina. Preliminary Objections, Merits, Reparations and Costs. Judgment of August 31, 2012. Series C No. 246, paras. 302 and 303, and Case of Mendoza et al. v. Argentina, supra note 73, para. 221. See also: Case of Gelman v. Uruguay. Monitoring Compliance with Judgment. Order of the Inter-American Court of Human Rights of March 20, 2013. Considering paras. 65 to 90. 77 Cf. Friendly settlement agreement and acknowledgment of the State’s responsibility, supra note 9, Section III. “Proceedings of the Case before the Inter-American System of Protection of Human Rights,” para. 8. 78 Cf. Judgment issued on April 18, 2013 by the First Collegiate Criminal Chamber of Texcoco in compliance with the appeal ruling issued on March 25, 2013 (case file of annexes to the pleadings and motions brief, pages 4456, 4457, 4620, 4797 and 4798). 79 It held that ‘‘‘immediacy’ as a principle characteristic of an adversarial criminal process clearly requires the judge to directly witness the submission of evidence presented by the parties and the adversarial examination to which they are mutually subjected. What should not be confused with the benchmark of evidence assessment has been termed obtaining prompt proceedings. This last concept should be reviewed in light of the principles and standards of due legal process.” Cf. Judgment in the direct amparo action 778/2012 handed down by the Collegiate Court of the Auxiliary Center Circuit of the Seventh Region on March 25, 2013. (Case Merits file, page 263). 80 Cf. Judgment in the direct amparo action 778/2012, supra note 79, page 262. 19