time referred to in Article 8.1 of the Convention must be analyzed in relation to the total duration of the proceeding until a final judgment is rendered.”161 96. The IACHR notes that the suit for damages lasted from December 18, 1990, the date of the filing of the complaint, until November 23, 2000, the date the final judgment was rendered. In the present case, the IACHR must also take into consideration that the judgment execution stage took another two years, until December 17, 2002, when the bonds were credited to the account of the plaintiff as the damages award. Therefore, a period of at least twelve years, from the time the complaint was filed until the bonds were credited, constitutes the period of time under examination by the IACHR in order to determine reasonableness. 97. The IACHR also finds it necessary to recall that the right to judicial protection would prove to be illusory if domestic law allowed a binding final judicial decision to remain ineffective to the detriment of one of the parties.162 Furthermore, “judgment enforcement is part of the legal process —the due process of the law— and, hence, the States must ensure that said enforcement is carried out within a reasonable time”.163 98. Additionally, the bodies of the Inter-American human rights system have referred to the elements that must be taken into account to determine reasonableness of time in a case –and thereby be able to determine whether the State has provided a “simple and prompt recourse” with due process guarantees within a reasonable time. These elements are: a) the complexity of the matter; b) the procedural activities carried out by the interested party; and c) the conduct of the judicial authorities.164 The Court has also established that in addition to these elements, the interest at stake and the adverse effect caused by the duration of the proceeding on the situation of the person involved must be taken into consideration, as is stated hereunder: In addition, the Court finds it pertinent to clarify that, in this analysis of reasonableness, the adverse effect of the duration of the proceedings on the judicial situation of the person involved in it must be taken into account; bearing in mind, among other elements the matter in dispute. If the passage of time has a relevant impact on the judicial situation of the individual, the proceedings should be carried out more promptly so that the case is decided as soon as possible. 165 161 IA Court HR, Case 11.400, Merits, Josefina Ghiringhelli De Margaroli y Eolo, Margaroli, Argentina, March 16, 2009, para. 90, citing the I/A Court H.R., Case of Salvador Chiriboga v. Ecuador. Preliminary Objection and Merits. Judgment of May 6, 2008. Series C No. 179, para. 56; I/A Court H.R., Case of Suárez Rosero v. Ecuador. Judgment of November 12, 1997. Series C No. 35, para. 70; I/A Court H.R., Case of López Álvarez v. Honduras. Judgment of February 1, 2006. Series C No. 141, para. 129; and I/A Court H.R., Case of Acosta Calderón v. Ecuador. Judgment of June 24, 2005. Series C No. 129, para. 104. 162 I/A Court H.R., Case of Acevedo Jaramillo et al v. Peru. Judgment of February 7, 2006. Series C No. 144, para. 219, citing ECHR, Antoneeto v. Italy, no. 15918/89, para. 27, ECHR, July 20, 2000; Immobiliare Saffi v. Italy [GC], no. 22774/93, para. 63, ECHR, 1999-V; and Hornsby v. Greece. Judgment of 19 March 1997, ECHR, Reports of Judgments and Decisions 1997-II, para. 40. 163 Reasoned Opinion of Judge A.A. Cançado Trindade to IA Court H/R Judgment in the Jaramillo case, para. 3. 164 IACHR, Report Nº 100/01, Case 11.381, Milton García Fajardo et al, Nicaragua, October 11, 2001. I/A Court H.R., Case of Genie Lacayo v. Nicaragua. Judgment of January 29, 1997. Series C No. 30, para. 77; I/A Court H.R., Case of Suárez Rosero v. Ecuador. Judgment of November 12, 1997. Series C No. 35, para. 72; I/A Court H.R., Case of Bayarri v. Argentina. Preliminary Objection, Merits, Reparation and Costs. Judgment of October 30, 2008. Series C No. 187, para. 107; and I/A Court H.R., Case of Valle Jaramillo et al v. Colombia. Merits, Reparation and Costs. Judgment of November 27, 2008. Series C No. 192, para. 155. 165 I/A Court H.R., Case of Valle Jaramillo et al v. Colombia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 192, para. 155. Also see, I/A Court H.R., Case of Kawas Fernández v. Honduras. Merits, Reparations and Costs. Judgment of April 3, 2009 Series C No. 196, paras. 112 and 115; I/A Court H.R., Case of Anzualdo Castro v. Peru. Preliminary Exception, Merits, Reparations and Costs. Judgment September 22, 2009. Series C No. 202, para. 156; I/A Court H.R., Case of Garibaldi v. Brazil. Preliminary Exceptions, Merits, Reparation and Costs. Judgment of September 23, 2009. Series C No. 203, para. 133; I/A Court H.R., Case of Radilla Pacheco v. Mexico. Preliminary

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