28 bringing an action before the Commission. Since the Commission did not use the authority established in Article 26(2) of its Rules of Procedure which enabled it to act motu proprio on the basis of any available information, even without an explicit petition by Mr. Griffith Davis' relatives, the Court concludes that it may rule only on the events that occurred in connection with Mr. Nicholas Blake. 86. The Court observes that Mr. Nicholas Blake's death, which occurred during his forced disappearance, was an act that was completed, according to testimonial evidence and the death certificate (supra 52 (a) and (m)), on March 28 or 29, 1985, that is, before the date on which Guatemala accepted the competence of the Court. Since in its July 2, 1996 judgment on preliminary objections this Court decided that it only had the competence to rule on the effects and acts subsequent to the date of recognition of its jurisdiction (March 9, 1987), this Tribunal considers that it may not rule on Mr. Nicholas Blake's death pursuant to Article 4 of the American Convention. XII VIOLATION OF ARTICLE 8(1) 87. On April 16, 1997, Guatemala human rights responsibility deriving administration of justice until 1995. It independent of the outcome of the case submitted a brief in which it accepted from the unwarranted delay in the went on to say that its acceptance was in the domestic courts (supra 27). 88. According to the Commission, the denial of justice in this case derives, inter alia, from the violation of the right to effective remedy, from the obstruction and delay of the relevant criminal process, since more than ten years have elapsed since Mr. Nicholas Blake's death and the case is still pending in the domestic courts. 89. The Court considers that, given the Guatemalan State's partial acceptance of responsibility until 1995 in this case, all the facts relating to the delay of justice until that time are presumed to be true. Moreover, the Court has no reason to restrict itself to that year, because the obstruction of justice has effects up to the present time since Mr. Nicholas Blake's murder and the case are still pending in the domestic courts. Therefore, Guatemala's responsibility continues and cannot be restricted to the aforementioned year. 90. The Court now examines the question of merits raised by the Commission in connection with Article 8(1) of the American Convention, which provides that Every person has the right to a hearing, with due guarantees and within a reasonable time, by a competent, independent, and impartial tribunal, previously established by law, in the substantiation of any accusation of a criminal nature made against him or for the determination of his rights and obligations of a civil, labor, fiscal, or any other nature. And Article 1(1) of the Convention establishes that The States Parties to this Convention undertake to respect the rights and freedoms recognized herein and to ensure to all persons subject to their jurisdiction the free and full exercise of those rights and freedoms, without any discrimination for reasons of race, color, sex, language, religion, political or other opinion, national or social origin, economic status, birth, or any other social condition. 91. The Commission pointed out that Guatemala's delay violated the rights recognized in Articles 25 and 8(1). The Convention bases the right to a trial "within a reasonable time" on the need to avoid unwarranted delays that