for grading the sanction pursuant to the gravity of the behavior], in breach of his right to defense. It added that "the type of defense and promotion of evidence, among others, introduced by the victim would be materially different from that which could be developed in the face of an administrative sanction that imposes an economic fine." Moreover, the Commission indicated that "the absence of a proceeding prevented Mr. López Mendoza from exercising his right to be heard regarding the appropriateness and proportionality of the sanction of disqualification." 135. The representatives indicated that there was no proceeding to “determine the severity of the offense and the type of damage caused, which were actually not existent.” In particular, the representatives argued that Mr. López Mendoza was “never provided with legal notice” of the “possibility of being subject [to] a disqualification” and that “there was no opportunity” to “defend [or contest] the seriousness of the facts and extent of the damage.” Moreover, they also noted that it was “impossible” for “a person who is not provided legal notice of the possible implementation” of additional sanctions “to be able to defend oneself in the substantiation of the administrative proceedings to determine responsibility, since it is impossible for the accused to know the extent of the damage and the severity of the crime when both have not yet been determined.” Thus, for the representatives “it is absolutely unsustainable” that "the procedures that led to the declaration of administrative responsibility and imposition of fines […] also represent the administrative proceedings for the sanction of disqualification,” as they had distinct purposes, cause, elements, and moreover, occurred much later. Thus, they questioned that the imposition of the additional sanction "does not require a different substantiation to that already previously issued by the Comptroller upon declaring the administrative responsibility." 136. Meanwhile, the State indicated that “for the imposition of the sanction of disqualification,” “there is no need to carry out a different proceeding than that in which administrative responsibility is declared” because “the proceeding is one of its kind” and “is of a complex nature.” It added that the alleged victim “exhausted, in the administrative and judicial forums, his constitutional right to plead and prove all that was necessary against the aforementioned sanction.” Regarding the alleged lack of correspondence between the principle sanction and the additional sanctions, the State indicated that the imposition of the sanction "understood as a whole, is that it should be externalized or motivated from the relationship that exists between the unlawful act and the sanction to be imposed.” 2.2 Considerations of the Court 137. Of the arguments made by the parties, the Court considers it necessary to analyze: i) the alleged lack of notice of the possible imposition of disqualification; ii) the alleged need to expose independent arguments and evidence in order to ensure the right to defense, and iii) the Comptroller's duty to establish cause when imposing the disqualification. 138. Regarding the alleged lack of notice of the possible imposition of an additional sanction, the expert Cabrera Romero noted that it was not necessary to provide notice that, as a result of a declaration of administrative responsibility, a sanction of disqualification was to be imposed, as that is "a matter of law, because the legislation so provides in Article 105 [of LOCGRSNCF]." 234 In this regard, the Court notes that Article 105 of the LOCGRSNCF is clear in pointing out the possibility that the Comptroller impose 234 report or expert witness Jesús Eduardo Cabrera Romero, supra note 31. 56