IV. LEGAL ANALYSIS A. Right to a Fair Trial and Judicial Protection (Articles 8(1)169 and 25(1)170 of the American Convention in connection with Article 1(1) thereof), with respect to the murder of Mr. García Valle 78. According to the consistent case law of the organs of the inter-American system, as a result of the protection granted by Articles 8 and 25 of the Convention, the States are obliged to provide effective judicial recourses to the victims of human rights violations that must be substantiated in accordance with the rules of due process of law.171 Furthermore, the Court has held that the right of access to justice should ensure, within a reasonable time, the right of the alleged victims or their next of kin to have everything necessary done to learn the truth about what happened and to investigate, try and, as appropriate, punish those responsible.172 That obligation, which relates to means rather than to results, must be assumed by the State as its own legal duty and not as a mere formality preordained to be ineffective.173 In this sense, the investigation should be undertaken with due diligence174, effectively, seriously, impartially, and within a reasonable period of time175. 79. Taking into account the unique characteristics of this case, the Commission recalls that the most effective way to protect human rights defenders is by effectively investigating the acts of intimidation or violence against them, and punishing the persons responsible.176 In that regard, the Inter-American Court has held that “the threats and attacks on the lives and personal integrity of human rights defenders, as well as the impunity enjoyed by those responsible for such acts, are particularly grave because they have not only individual, but also collective effects, inasmuch as society is prevented from learning the truth concerning the 169 Article 8(1) of the American Convention provides: 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. 170For its part, Article 25 of the American Convention states: 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. 171 I/A Court H.R. Case of Rodríguez Vera et al. (Persons Disappeared from the Palace of Justice) v. Colombia. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 14, 2014. Series C No. 287, par. 435, citing Cf. Velásquez Rodríguez Case v. Honduras. Preliminary Objections. Judgment of June 26, 1987. Series C No. 1, par. 91; and Case of Human Rights Defender et al. v. Guatemala. Preliminary Objections, Merits, Reparations and Costs. Judgment of August 28, 2014. IACHR, Annual Report 2011, OEA/Ser.L/V/II., Doc. 283, par. 199. 172 I/A Court H.R. Case of Rodríguez Vera et al. (Persons Disappeared from the Palace of Justice) v. Colombia. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 14, 2014. Series C No. 287, par. 435. Citing. Cf. Case of Bulacio v. Argentina. Merits, Reparations and Costs. Judgment of September 18, 2003. IACHR, Annual Report 2011, OEA/Ser.L/V/II., Doc. 100, para. 114; and Case of Human Rights Defender et al. v. Guatemala. Preliminary Objections, Merits, Reparations and Costs. Judgment of August 28, 2014. IACHR, Annual Report 2011, OEA/Ser.L/V/II., Doc. 283, par. 199. 173I/A Court H.R., Velásquez Rodríguez Case v. Honduras. Merits. Judgment of July 29, 1988. Series C No. 4, par. 177; I/A Court H.R., Case of Cantoral-Huamaní and García-Santa Cruz v. Peru. Preliminary Objection, Merits, Reparations and Costs. Judgment of July 10, 2007. IACHR, Annual Report 2011, OEA/Ser.L/V/II., Doc. 167, par. 131. 174I/A Court H.R., Case of García-Prieto et al. v. El Salvador. Preliminary Objection, Merits, Reparations and Costs. Judgment of November 20, 2007, Series C No. 168; IACHR, Annual Report 2011, OEA/Ser.L/V/II., Doc. 168, par. 101; I/A Court H.R., Case of the Gómez Paquiyauri Brothers. v. Peru. Judgment of July 8, 2004. IACHR, Annual Report 2011, OEA/Ser.L/V/II., Doc. 110, par. 146; I/A Court H.R., Case of Cantoral-Huamaní and García-Santa Cruz v. Peru. Preliminary Objection, Merits, Reparations and Costs. Judgment of July 10, 2007. IACHR, Annual Report 2011, OEA/Ser.L/V/II., Doc. 167, par. 130. 175 I/A Court H.R., Case of Bulacio Vs. Argentina. Sentencia de 18 de septiembre de 2003. Serie C No. 100, par. 114; I/A Court H.R., Case of Masacre de la Rochela Vs. Colombia. Judgment of May 11, 2007. Series C. No. 163, par. 146; I/A Court H.R., Case of Penal Miguel Castro Castro Vs. Perú. Judgment of November 25, 2006. Series C No. 160, par. 382. 176IACHR, Report No. 56/12, Merits (Florentín Gudiel Ramos, Makrina Gudiel Álvarez et al.), Guatemala, March 21, 2012, par. 126; IACHR, Access to Justice for Women Victims of Violence in the Americas, OEA/Ser. L/V/II. doc.68, January 20, 2007, par. 112. IACHR, Report on the Situation of Human Rights Defenders in the Americas OEA/Ser.L/V/II.124. Doc. 5 rev.1, March 7, 2006.