date of notification of the final decision. Article 32(2) of the Rules of Procedure of the IACHR provides in this respect: In those cases in which the exceptions to the requirement of prior exhaustion of domestic remedies are applicable, the petition shall be presented within a reasonable period of time, as determined by the Commission. For this purpose, the Commission shall consider the date on which the alleged violation of rights occurred and the circumstances of each case. 48. The petition that gave rise to the consideration of this case is dated January 3, 1996. However, the petitioner states that he forwarded via APRODEH a petition dated January 13, 1995, as well as a fax dated March 15, 1995 that referred to the petition. While the Commission has no record of the receipt of any of these documents on the dates indicated, the file does contain a number of communications sent by fax by the petitioner from April 27, 1995.22 49. Bearing in mind that the filing of the complaint brought by the petitioner before the Office of the Attorney-General was ordered by decision of May 8, 1998 and that, as stated in the note transmitted to the Inter-American Commission on September 15, 2002, that decision was notified to the petitioner in 2001, in the view of the Commission, based on the above considerations, the petition was presented within a reasonable period. 3. Duplication of international procedures and international res judicata 50. The file on the petition contains no information whatsoever that might lead to the conclusion that the instant case is pending in another forum for international settlement or that it had been previously decided by the Inter-American Commission. The Commission therefore concludes that the exceptions provided for in Article 46(1)(d) and in Article 47(d) of the American Convention are not applicable. 4. Characterization of the acts alleged 51. The allegations of the petitioner refer to his alleged illegal detention under Decree Law No. 25475 on terrorism, detention at a military base for 31 days, being held incommunicado, psychological torture, and the failure to investigate and punish those responsible for these acts. For its part, the Peruvian State alleges that the acts do not constitute possible violations of the American Convention. 52. It is not necessary to establish at the present stage of the proceeding whether the American Convention has indeed been violated. For the purposes of admissibility, the Commission must determine whether the acts described constitute a violation, as provided for in Article 47(b) of the American Convention. The criteria for evaluation of these matters are different from the criteria that must be used to decide on the substance of a complaint. The Inter-American Commission must undertake a prima facie review to determine whether the complaint is based on the apparent or potential violation of a right guaranteed in the American Convention. This is a summary analysis that does not prejudice or advance an opinion on the substance of the dispute. The distinction between the study of the declaration of admissibility and the study required to determine whether a violation has taken place is set out in the Commission's Rules of Procedure, which establish in a clearly differentiated manner the phases of admissibility and substance. 53. The allegations of the petitioners relate to acts that, were they true, would constitute violations of various of the rights guaranteed by the American Convention. Despite the fact 22 The petitioner sent similar faxes and letters on June 26, 1995, on July 7, 1995, on October 19, 1995, on September 1, 1995 and on December 21, 1995. On February 8, 1996, APRODEH transmitted a copy of a complaint dated January 13, 1995 that had been sent to the Commission in 1995 but which had apparently gone astray. 9