53. Second, the Commission notes that apart from the absence of regulations on the authority of the Legislative Assembly, there were also no rules whatever on the procedure to follow, which would have afforded Mr. Colindres foreknowledge of what steps he should follow, how to exercise his defense, and what remedies would be available to him in the event of an unfavorable decision. That guarantee is also envisaged in Article 8(1) of the Convention. 54. The Commission finds that although the State is empowered to dismiss government officials, including judges who commit the disciplinary faults envisaged by the law as grounds therefor, to exercise that power the State has the responsibility to establish the necessary institutional framework, including express rules on competencies and procedures, so that it may use that power in a manner consistent with its international obligations, particularly those relating to due process, which, as mentioned, are strengthened where judicial authorities are concerned. 55. Bearing in mind the foregoing, the Commission concludes that the Legislative Assembly lacked the authority to remove Judge Colindres from office and that the State had not previously adopted regulations governing the applicable procedures for dismissing members of the tribunal to which he belonged. Consequently, the State of El Salvador bears responsibility for violation of Article 8(1) of the Convention to the detriment of Mr. Colindres, in relation to the obligations established in Article 1(1) of that treaty. Furthermore, given that under Article 2 of the Convention, States are required to adopt necessary measures to “harmonize [their] domestic law” with respect to “the procedure to be followed and the competent bodies to decide disciplinary proceedings,”84 the Commission considers that the State also violated Article 2 of the American Convention. 56. It having been determined that the Legislative Assembly was not the competent body in this case and that there was no previously established procedure, all the decisions that flowed from that body in the framework of the ad hoc procedure that was adopted in the case violated Article 8 of the American Convention, rendering it unnecessary to analyze the other guarantees of due process.85 The foregoing notwithstanding, in order that the State may adopt appropriate measures to avoid a recurrence of events such as those that occurred in the instant case, the Commission considers it pertinent to analyze the guarantees that apply to a disciplinary procedure of the kind instituted against Mr. Colindres. b. Impartiality of the Disciplinary Authority 57. Judge Colindres was removed from office by the Legislative Assembly; in other words, a political organ. Broadly speaking, the inter-American system has recognized impeachment as a legitimate form of control.86 However, because of its nature, giving the legislative branch the power to separate judges from office is problematic vis-à-vis the guarantee of independence.87 The Commission is of the view that “the use of impeachment in the case of justice operators should be gradually eliminated in the region, as impeachment poses a significant threat to judicial independence.”88 84 I/A Court H.R., Case of López Lone et al. v. Honduras. Preliminary Objection, Merits, Reparations and Costs. Judgment of October 5, 2015, Series C No. 302, par. 215. 85 I/A Court H.R., Case of Camba Campos et al. v. Ecuador. Preliminary Objection, Merits, Reparations and Costs. Judgment of August 28, 2013. Series C No. 268, par. 223 and Case of López Lone et al. v. Honduras. Preliminary Objection, Merits, Reparations and Costs. Judgment of October 5, 2015, Series C No. 302, par. 241. 86 IACHR, Case 12.600 Hugo Quintana Coello et al. (CSJ) v. Ecuador (Merits), August 2, 2011, par. 84. In the case of the Constitutional Tribunal v. Peru, the Inter-American Court stated that: Under the rule of law, the impeachment proceeding is a means of controlling senior officials of both the Executive and other State organs exercised by the Legislature. However, this control does not mean that the organ being controlled—in this case the Constitutional Court—is subordinate to the controlling organ—in this case the Legislature; but rather that the intention of the latter is that an organ that represents the people may examine and take decisions on the actions of senior officials. I/A Court H.R., Case of the Constitutional Court v. Peru. Judgment of January 31, 2001. Series C No. 71, par. 63. 87IACHR, Guarantees for the Independence of Justice Operators, December 5, 2013, par. 204. 88IACHR, Guarantees for the Independence of Justice Operators, December 5, 2013, par. 205. 14