3.4 Reasonable time 144. Article 8(1) of the American Convention establishes as one of the elements of a fair trial that tribunals reach a decision on cases submitted for their consideration within a reasonable time. Therefore, a long delay may per se constitute a violation of the principle of due process.216 Therefore, it is for the State to explain and prove why it has required more time than would be reasonable to deliver final judgment in a specific case.217 145. In that connection, reasonableness of time must be analyzed with regard to the total duration of the criminal process.218 Pursuant to Article 8(1) of the American Convention, the Commission will consider, in light of the specific circumstances of the case, the four elements that the Court has taken into account in its recent case-law: (i) the complexity of the case; (ii) the procedural activity of the interested party; (iii) the conduct of the judicial authorities; and (iv)) the general effects on the legal situation of the person involved in the proceeding.219 146. As a preliminary matter, the Commission notes that the facts in the case occurred on October 5, 1995 and that the conviction of 14 members of the Army patrol was handed down on July 8, 2004. Thereafter, following various appeals filed by the accused's defense, the Supreme Court of Justice declared the judgment final on September 23, 2005. 147. With respect to complexity, as the Court wrote, a delay in an investigation cannot be justified by the complexity of the matter when (i) possible perpetrators have been identified; (ii) it has been verified that there were witnesses to the event, and (iii) there are possible lines of investigation.220 The IACHR notes that there was no dispute with respect to the alleged participation of the Army patrol, whose members were suitably identified. There were also several witnesses, survivors of the massacre, who watched the events occur. In any event, for the complexity argument to be valid, the State must provide specific information linking the complexity to the delay, which has not happened in this case. 148. As to the activity of the authorities in charge of the proceedings, the Commission refers to the shortcomings analyzed in the two preceding sections in which mention is made of periods of inactivity as well as various irregularities and omissions. 149. As for the participation of interested parties, the Commission observes that in first place, the next of kin and witnesses have actively contributed to the case by making statements in the proceedings. Likewise, their legal representatives were appointed as civil parties to the proceedings, and therefore they ensured follow-up and promotion of the investigation, complaining on repeated occasions about the delay in processing the proceedings, as well as long periods of inertia in the proceedings. In terms of the conduct of 216 IACHR. The Right to Truth in the Americas, OEA/Ser.L/V/II.152, August 13, 2014, para. 133. I/A Court H.R., Case of García Asto and Ramírez Rojas v. Peru. Judgment of November 25, 2005. Series C No. 137, par. 166; Case of Gómez Palomino v. Peru. Merits, Reparations and Costs. Judgment of November 22, 2005. Series C No. 136, par. 85; and I/A Court H.R., Case of the Moiwana Community v. Suriname. Judgment of June 15, 2005. Series C No. 124, par. 160, 217 par. 142. I/A Court H.R., Case of Ricardo Canese v. Paraguay. Judgment of August 31, 2004. Series C No. 111, 218 I/A Court H.R., Case of López Álvarez v. Honduras. Judgment of February 1, 2006. Series C No. 141, par. 129; I/A Court H.R., Case of Acosta Calderón v. Ecuador. Judgment of June 24, 2005. Series C No. 129, par. 104; and I/A Court H.R., Case of Tibi v. Ecuador. Judgment of September 7, 2004. Series C No. 114, par. 168; IACHR, Report No. 77/02, Case 11.506, Merits, Waldemar Gerónimo Pinheiro and José Víctor dos Santos, Paraguay, December 27, 2002, par. 76. 219 I/A Court H.R., Case of the Santo Domingo Massacre v. Colombia. Preliminary Objections, Merits and Reparations. Judgment of November 30, 2012. Series C No. 259, par. 164. 220 I/A Court H.R., Case of the Barrios Family v. Venezuela. Merits, Reparations and Costs. Judgment of November 24, 2011. Series C No. 237, par. 275. 32