121. In addition, the IACHR notes that almost two years elapsed before a statement was taken from Mr. Gómez's father. A statement was also requested from the lawyer of the trade union of which Mr. Gómez was a member. Nevertheless, that person never turned up and there is no evidence of the State taking any steps to ensure that he did. 122. Later on, the Public Prosecutors' Office requested that the investigation be archived due to "the discrepancy between witnesses' versions regarding who should be suspected of perpetrating the crime and the failure of persons summonsed to appear." The Commission considers that the request to archive the case because of the existence of different versions of what happened without exhausting even basic investigative procedures, much less the possibilities of throwing light on the discrepancies, is a move incompatible with the obligation to investigate with due diligence. 123. Even though the judge overseeing the case denied the request of the Public Prosecutors' Office, there have been no signs since 1997 of any steps to investigate the disappearance and subsequent death of Mr. Gómez, throw light on the circumstances in which it occurred, and punish those responsible. This lack of effort and diligence on the part of the authorities is especially serious in light of the absence of practically any indications of investigation in the file on the case. 3. Reasonable period of time 124. 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. Accordingly, unwarranted delay may, in itself, constitute a violation of judicial guarantees.131 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.132 Thus, how reasonable the period of time taken is has to be assessed in relation to the total duration of the criminal proceedings133 and in light of the four elements that Court has considered in its case law: (i) the complexity of the matter; (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. 134 125. As far as complexity is concerned, the State merely indicated that the two suspects in Mr. Gómez's death were fugitives from justice. In that regard, the IACHR considers that for a complexity argument to be valid the State must provide specific information directly connecting the elements of complexity invoked to the delays in the proceeding. That has not happened in this case. 126. As to the activities of the interested parties, the Commission finds nothing whatever in the record to suggest that the relatives obstructed the proceeding or could be blamed in any way for the delay. As to the conduct of the judicial authorities, the Commission has already established in this report that there was a breach of the obligation to act with due diligence in the criminal investigation. Having reached these conclusions, the IACHR does not consider it necessary to analyze the fourth element. 127. Bearing in mind the ambiguity of the information as to whether the investigation was formally archived, the Commission considers that the more than 21 year that have elapsed since the complaint was filed regarding the disappearance and subsequent death of Mr. Gómez constitutes an excessive period of time that the State has not justified. Therefore, the Commission finds that the State violated the reasonable-time rule. 4. Conclusion 131 I/A Court HR. Case of García Asto and Ramírez Rojas v. Peru. Judgment of November 25, 2005. Series C No. 137, par. 166. 132 I/A Court HR. Case of Ricardo Canese v. Paraguay. Judgment of August 31, 2004. Series C No. 111, par. 142. 133 I/A Court HR. Case of López Álvarez v. Honduras. Judgment of February 01, 2006. Series C No. 141, par. 129. I/A Court HR. Case of the Massacre of Santo Domingo v. Colombia. Preliminary Objections, Merits and Reparations. Judgment of November 30, 2012. Series C No. 259, par. 164. 134 22