recognized that forced disappearance entails suppression of the right to be recognized as a person before the law.126 127. According to the established facts in the instant case, Mr. Jorge Vásquez Durand was the victim of a forced disappearance perpetrated by Ecuadorian army personnel. For that reason, and based on the foregoing considerations, the IACHR concludes that the Ecuadorian State failed to fulfill its obligations to respect and guarantee the rights established in article 3 of the American Convention, in conjunction with article 1.1 of the same instrument, to the detriment of Mr. Jorge Vásquez Durand. 3. 128. the following: Right to due guarantees and judicial protection (American Convention on Human Rights) in connection with the obligation to respect human rights and the duty to adopt measures under domestic law (Article 1.1 and 2 of the same Convention) and article 1.b of the Inter-American Convention on Forced Disappearance of Persons The articles of the American Convention referred to in the heading to this section establish Article 8.1. Judicial Guarantees Every person has the right to a hearing, with due guarantees and within a reasonable time, by a competent, independent, and impartial tribunal, previously established by law, in the substantiation of any accusation of a criminal nature made against him or for the determination of his rights and obligations of a civil, labor, fiscal, or any other nature. Article 25.1 Judicial Protection Everyone has the right to simple and prompt recourse, or any other effective recourse, to a competent court or tribunal for protection against acts that violate his fundamental rights recognized by the constitution or laws of the state concerned or by this Convention, even though such violation may have been committed by persons acting in the course of their official duties. Article 1.1 Obligation to Respect Rights The States Parties to this Convention undertake to respect the rights and freedoms recognized herein and to ensure to all persons subject to their jurisdiction the free and full exercise of those rights and freedoms, without any discrimination for reasons of race, color, sex, language, religion, political or other opinion, national or social origin, economic status, birth, or any other social condition. Article 2. Domestic Legal Effects [duty to adopt measures under domestic law]: Where the exercise of any of the rights or freedoms referred to in Article 1 is not already ensured by legislative or other provisions, the States Parties undertake to adopt, in accordance with their constitutional processes and the provisions of this Convention, such legislative or other measures as may be necessary to give effect to those rights or freedoms. 129. Article I (b) of the Inter-American Convention on Forced Disappearance of Persons establishes that the States Parties to this Convention undertake "to punish within their jurisdictions, those persons who commit or attempt to commit the crime of forced disappearance of persons and their accomplices and accessories.” 130. Furthermore, the Inter-American Convention on Forced Disappearance of Persons obliges the States to "ensure that the training of public law-enforcement personnel or officials includes the necessary education on the offense of forced disappearance of persons" (article VIII). As the IACHR has established, this provision is also pertinent with respect to the training of police and (civilian or military) penitentiary personnel, "especially because one of the risks incurred by an illegally detained person is precisely that he or she may become a victim of forced 126 I/A Court H.R, Case of Anzualdo Castro v. Peru. Judgment of September 22, 2009, Series C No. 202, paragraph 90. 30