62 230. The Court has also established that the obligation to investigate, and the corresponding right of the presumed victims or their next of kin is evident not only from the treaty-based norms of international law that are binding for the States Parties, but also arise from domestic laws concerning the duty to investigate ex officio certain unlawful conducts, and from norms that allow the victims or their next of kin to file complaints or submit claims, evidence or petitions or take any other step in order to play a procedural role in the criminal investigation to establish the truth of the events.232 231. In this case, the representatives and the Commission argued that the State is responsible for the violation of the rights enshrined in Articles 8(1) and 25 of the Convention, in relation to 1(1) of the same due to the following: a) the alleged lack of effectiveness of the remedies to obtain recognition of communal property; b) the alleged lack of effectiveness of the judicial and administrative actions regarding the sales and allocation of traditional lands to third parties, and c) the alleged lack of investigation of the threats and murders of members of the Community of Triunfo de la Cruz. Below, the Court will analyze the alleged violations in that order. B.1. The alleged lack of effectiveness of the remedies to obtain recognition of communal property 232. First, the Court verifies that the arguments regarding the existence of an adequate procedure for the titling, demarcation, and delimitation of the collective property of the Garífuna Community of Triunfo de la Cruz were already analyzed in Chapter VII-2 on the duty to adopt domestic provisions. In this chapter reference will be made only to the effectiveness of the stated mechanisms. 233. From 1946 to 2001 the Community of Triunfo de la Cruz filed several requests for the titling of different territories: a) in 1946 the Community requested the granting of a communal title deed over 380 hectares corresponding to the land occupied by them (supra para. 59); b) on June 27, 1969, under the protection of the Law on Agrarian Reform, fifty members of the Community of Triunfo de la Cruz filed a request before the Regional Agrarian Office of the INA for the creation of an “agricultural population center” (supra para. 60), which was still unresolved in 1996 (supra para. 66). There is no information on this procedure’s current status; c) in 1979 the Community filed a request before the INA that resulted in that institution issuing the Community a title of “guarantee of occupation” over 126.40 hectares on September 28, 1979 (supra para. 68); d) in 1993, the Community requested, based on the Law for the Modernization and Development of the Agricultural Sector of 1992, the granting of a final deed of full ownership over the 380 hectares granted as communal land in 1950. On October 29, 1993 the Community was issued, without cost, a “final property deed in full ownership” over that area (supra para. 69); e) on August 28, 1997 and on July 8, 1998, the Community of Triunfo de la Cruz and its members requested a title deed of full ownership before the INA for the rest of the lands they stated they had historically occupied in 1997 and 1998. The first request referred to a 600-hectare area and the second request to a land of 126.40 hectares they already possessed in guarantee of occupation (supra para. 70). On September 232 184. Cfr. Case of the Barrios Family v. Venezuela, para. 80, and Case of Veliz Franco et al. v. Guatemala, para.