76 217. Meanwhile, regarding the alleged violation of reasonable time argued by the representatives, the Court refers back to previous rulings in which it has indicated that, for the investigation to be conducted seriously, impartially and as an inherent legal duty, the right of access to justice requires that the events investigated are clarified within a reasonable time.320 The Court has stated that the “reasonable time” referred to in Article 8(1) of the Convention must be assessed in relation to the total duration of the proceedings up until the final judgment is handed down. 321 The Court considers that, in principle, a prolonged delay, such as the one that occurred in this case, constitutes, of itself, a violation of judicial guarantees.322 218. In the instant case, the Court underlines that, as the State itself has acknowledged, the investigation was delayed for at least eight months at the start during the jurisdictional dispute between March 11 and November 21, 2002 (supra para. 19). It should be pointed out that, although it is permissible to raise a concern about jurisdiction323 as this is regulated in the Guatemalan Code of Criminal Procedure,324 it is also essential that a dispute of this type be decided promptly in order to avoid delays in the investigation or the criminal proceedings. The case files provided by the parties show that, while the jurisdictional dispute lasted, only one substantive investigative measure was ordered by the Mixco First Court and various communications were processed.325 However, a note signed by an agent of the Mixco Prosecutor’s Office indicates that this Office had not continued the investigation because it had received instructions from its superior not to proceed with it, because it did not have competence to do so, and indicated that when the judge had decided the jurisdiction dispute, the file would be sent to Mixco Agency No. 5.326 Based on the State’s acknowledgement and on the foregoing, the Court finds that the jurisdictional dispute led to a period of inactivity in the investigation of around eight months. 219. There were also other prolonged periods of inactivity. Thus, the facts reveal that 320 Cf. Case of Hilaire, Constantine and Benjamín et al. v. Trinidad and Tobago. Merits, reparations and costs. Judgment of June 21, 2002. Series C No. 94, para. 14, and Case of García and family members, supra, para. 152. 321 Cf. Case of Suárez Rosero v. Ecuador. Merits. Judgment of November 12, 1997. Series C No. 35, paras. 70 and 71, and Case of Mémoli v. Argentina. Preliminary objections, merits, reparations and costs. Judgment of August 22, 2013. Series C No. 265, para. 171. 322 Cf. Case of Hilaire, Constantine and Benjamín et al., supra, para. 229, and Case of Osorio Rivera and family members, supra, para. 192. 323 Matters relating to competence are regulated in articles 56 to 61 of the Fifth Section of the Guatemalan Code of Criminal Procedure. Cf. Congress of the Republic of Guatemala. Code of Criminal Procedure. Decree 51-92 and its amendments, supra. 324 The pertinent part of article 332 indicates that “[t]he purpose of the intermediary stage is for the judge to assess whether or not there are grounds to subject a person to a public and oral trial, based on the probability of participation in a crime or to verify the substantiation of the other requests of the Public Prosecution Service”. Cf. Congress of the Republic of Guatemala. Code of Criminal Procedure. Decree 51-92 and its amendments, supra. 325 Ruling of March 26, 2002, issued by the First Instance Court of Mixco indicating that it “has before it for a decision the memorandum presented by the prosecutor of the Public Prosecution Service […], in which he requests […] that the Court require the list of telephone calls from [several] telecommunications companies,” and indicating that “after examining this case, the judge who supervises the investigation considers that it is in order to grant this request, and this consists in GRANTING AUTHORIZATION to request the list of telephone calls to the telecommunications companies.” In other words, the judge only ordered one procedure, even though different notes were processed. Cf. Note C-105-2002/6º issued by the First Instance Court of Mixco, supra. In addition, there are requests by the Prosecutor of Guatemala City Agency No. 32 to the Bureau of Criminal Investigation of the Public Prosecution Service that it send investigators to this Agency to give them new guidelines and more details of the investigation. Cf. Note of September 26, 2002, of the Assistant Prosecutor of Guatemala City Agency No. 32 (file of annexes to the answering brief, annexes 3-3b, f. 13,228). 326 Cf. Note of an agent of the Mixco Agency to the Deputy Executive Secretary of the Public Prosecution Service, supra. It should also be noted that Article 312 established that the “request concerning lack of competence does not exempt the Public Prosecution Service from the duty of conducting urgent investigation procedures.” Cf. Congress of the Republic of Guatemala. Code of Criminal Procedure. Decree 51-92 and its amendments, supra. The State referred to the Code of Criminal Procedure of Guatemala, Decree 51-92, and also to the Organic Law of the Public Prosecution Service, Decree 40-94, and to the Law of the Judiciary, Decree 2-89.