responsibility for the proceedings that arise from these facts.” 784 However, it was not until October 28, 2013, almost two years later (one year and 10 months) and on the occasion of the hearings held in the instant case, that the Prosecution Service advised that it had decided to combine in a single special unit all the investigations into the events that occurred in the Palace of Justice on November 6 and 7, 1985 (supra para. 208). The Court assesses positively the integration of the investigations into the events of this case into a single special unit of the Prosecution Service, which may make a positive contribution to their effectiveness. However, it notes that the obligation to investigate must be complied with by the State as an inherent legal duty and not with a view to the State’s defense before this Court. 504. The Court also notes that, after 29 years, the State’s main defense and the decisions of two chambers of the Superior Court of Bogota (in the two cases that to date have been decided in second instance) rests, above all, on the absence of sufficient proof or on doubts arising from the errors committed during the initial procedures. Many of these errors (in the processing of the crime scene and the removal of the corpses) cannot be completely rectified. However, the Court notes that no serious, planned, and coordinated effort has been made to overcome these irregularities insofar as possible. The Court finds it particularly relevant that, despite this lapse of time, no pertinent measures have been taken to verify definitively whether the remains returned to the family of Justice Pedro Elías Serrano really belong to Norma Constanza Esguerra, which has been suspected since at least 1986 (supra para. 326). B.6) Reasonable time of the proceedings in the ordinary criminal jurisdiction 505. For the investigation to be conducted in a serious and impartial manner and as an inherent legal obligation, the right of access to justice requires that the facts investigated are determined within a reasonable time. 785 This Court has indicated that the “reasonable time” referred to by Article 8(1) of the Convention must be assessed in relation to the total duration of the proceedings until a final judgment is handed down. 786 The Court considers that, in principle, a prolonged delay, such as the one that has occurred in this case constitutes, of itself, a violation of judicial guarantees. 787 506. The Court has generally considered the following elements to determine whether the time is reasonable: (a) the complexity of the matter; (b) the procedural activity of the interested party; (c) the actions of the judicial authorities, and (d) the effects on the legal situation of the person involved in the proceedings. The Court recognizes that there have been periods during which the investigations in this case have been conducted with due diligence and respecting the guarantee of a reasonable time. In particular, the Court has recognized that most of the procedures in the investigation were carried out between 2005 and 2010, while, since 2010, criminal proceedings have been held and several judgments have been handed down in relation to those investigations (supra para. 497). However, in the instant case, 29 years have passed since the events, and what occurred has still not 784 Judgment of the Superior Court of Bogota of January 30, 2012 (evidence file, folio 23454). 785 Cf. Case of Baldeón García v. Peru. Merits, reparations and costs. Judgment of April 6, 2006. Series C No. 147, para. 155, and Case of the Landaeta Mejías Brothers et al. v. Venezuela. Preliminary objections, merits, reparations and costs. Judgment of August 27, 2014. Series C No. 281, footnote 314. 786 Cf. Case of Genie Lacayo v. Nicaragua. Merits, reparations and costs. Judgment of January 29, 1997. Series C No. 30, para. 77, and Case of the Landaeta Mejías Brothers et al. v. Venezuela. Preliminary objections, merits, reparations and costs. Judgment of August 27, 2014. Series C No. 281 , footnote 314. 787 Cf. Case of Suárez Rosero v. Ecuador. Merits. Judgment of November 12, 1997. Series C No. 35, para. 71, and Case of the Human Rights Defender et al. v. Guatemala. Preliminary objections, merits, reparations and costs. Judgment of August 28, 2014. Series C No. 283, para. 226. 177

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