procedural action until the judgment is definitively issued. 57 In accordance with Article 8(1) of the Convention and as part of the right to justice, proceedings must take place within a reasonable time, 58 so a significant delay can become, in itself, a violation of judicial guarantees. 59 This Court recalls that the four elements it has considered to determine the reasonableness of the duration are: i) the complexity of the issue, ii) the procedural actions of the party, iii) the conduct of the legal authorities, and iv) the effects of the legal situation on the person involved in the trial. 60 93. In this case, even though there is no record of actions for almost a year at the beginning of the trial, that was due to the fact that Mr. Carranza had not been located, and the facts of the case and the arguments of the parties do not allow for the conclusion that the length of that delay was the fault of the State. It is appropriate then, in the present case, to focus the evaluation on the four other years, from the point at which Mr. Carranza was arrested to the issuance of the guilty verdict against him. 94. First, the facts that the case do not indicate complexity: It was a crime with one victim, committed in the presence of other people, and the presumed perpetrators were identified in the initial report. Second, after Mr. Carranza was deprived of his liberty, there is no record supporting the conclusion that he obstructed the conduct of the proceedings in any way. Moreover, regarding the third and fourth elements, the abovementioned delays of approximately three years while Mr. Carranza was deprived of his liberty adversely affected his rights. 95. The foregoing shows that there were delays for close to three out of the approximately four years of the criminal trial against Mr. Carranza after he was arrested. 96. Thus, the Court considers that Ecuador violated, to the detriment of Mr. Carranza, the judicial guarantees set forth in Article 8(1) of the Convention by not bringing the criminal trial to a close within a reasonable time. B.6 Conclusion 97. The Court determines that, in the terms indicated in the preceding paragraphs, Ecuador violated the rights of personal liberty and judicial guarantees, as both the order for preventive detention in the case and the continuation thereof were arbitrary and contrary to the presumption of innocence, in violation of Articles 7(1), 7(3), and 8(2) of the American Convention on Human Rights, to the detriment of Ramón Rosendo Carranza Alarcón, in relation to the obligation to respect the rights and to adopt domestically the legal provisions set forth in Articles 1(1) and 2 of the Convention respectively. Furthermore, regarding the obligation to respect rights, the State violated Mr. Carranza’s right to personal liberty with respect to the Convention’s right to be tried within a reasonable time or be released. It also violated his right to judicial guarantees Cf. Case of Suárez Rosero v. Ecuador. Merits, paras. 70 and 71; Case of López Álvarez v. Honduras, para. 129, and Case of Jenkins v. Argentina, para. 106. 57 Cf. Case of Bulacio v. Argentina. Merits, Reparations, and Costs. Judgment of September 18, 2003. Series C No. 100, para. 114, and Case of Perrone and Preckel v. Argentina, para. 141. 58 59 Cf. Case of Hilaire, Constantine, and Benjamin et al. v. Trinidad and Tobago. Merits, Reparations, and Costs. Judgment of June 21, 2002. Series C No. 94, para. 145, and Case of Jenkins v. Argentina, para. 106. Cf. Case of Genie Lacayo v. Nicaragua. Merits, Reparations, and Costs. Judgment of January 29, 1997. Series C No. 30, para. 77; Case of Valle Jaramillo et al. v. Colombia. Merits, Reparations, and Costs. Judgment of November 27, 2008. Series C No. 192, para. 155, and Case of Jenkins v. Argentina, para. 106. 60 22