inasmuch as this creates a general impression of tolerance toward the acts of abuse, which reproduces more acts of violence against them, leaving them defenseless and unprotected.121 2. Reasonable time 119. The Commission recalls that Article 8(1) of the Convention establishes as one of the guarantees of a fair trial that tribunals must reach a decision on cases submitted for their consideration within a reasonable time. The Inter-American Court has found that a prolonged delay may constitute, in itself, a violation of the right to a fair trial,122 and that, 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. 120. In that respect, a reasonable time must be understood in regard to the total duration of the criminal proceedings.123 According to the terms of Article 8.1 of the American Convention, the Commission shall take into consideration, in the light of the concrete circumstances of the case, those elements that bodies of the Inter-American System have taken into account, namely: i) the complexity of the case; ii) the procedural activity of the interested party; and iii) the conduct of judicial authorities; and iv) the impact arising from the legal situation of the person involved in the proceedings. 124 121. As for these elements, the State alleged that the instant case is complex because of the events, which took place in the context of a confrontation; the victims were caught in a situation of flagrante delicto; and that the versions of the family members are not supported by other testimony. On this score, the IACHR reiterates firstly the considerations described above regarding the way in which the criminal investigation and trial proceedings were conducted, particularly, the value attached to the official version of the confrontation without exhausting the lines of investigation connected to the version of the family members and other witnesses. 122. Secondly, the IACHR finds that the elements of fact argued by the State to support the complexity of the case are totally unrelated as far as causality to the delay in the proceedings. Thus, for example, the Commission fails to see how the situation of flagrante delicto the victims were allegedly caught in is relevant or connected to the complexity of the investigation into their deaths. Similarly, the evidence in the case file does not support the claim that the version of the family members is not supported by other testimony, as born out in the proven facts section. In addition to the elements of fact invoked by the State not being relevant to establishing complexity, the Commission underscores that other elements of fact prove the opposite. Such as, from the beginning, the security force involved in the incidents was identified and an investigation was opened in order to be able to get to the bottom of them. Moreover, the victims were fully identified and the authorities had access, from the very beginning, to all exhibits of criminal forensic interest in order to conduct the necessary expert witness tests. In said context, the Commission finds that, while the instant case was about the decision on legitimate use of force, for which the State should have implemented the necessary mechanisms of due diligence, it did not involve a degree of complexity so as to justify a delay of more than 14 years since the events took place to elucidate and establish the respective liability for them. 121 IACHR. Report No. 11/10. Case 12.488. Merits. Barrios Family Members. Venezuela. March 16, 2010, para. 232. 122I/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. Judgment of November 22, 2005. Series C No. 136, par. 85; Case of the Moiwana Community v. Suriname. Judgment of June 15, 2005. Series C No. 124, par. 160. 123 I/A Court H.R., Case of López-Álvarez v. Honduras. Judgment of February 1, 2006. Series C No. 141, para. 129; Case of AcostaCalderón v. Ecuador. Judgment of June 24, 2005. Series C No. 129, para. 104; and Case of Tibi v. Ecuador. Judgment of September 7, 2004. Series C No. 114, para. 168. See also: IACHR, Report No. 77/02, Case 11.506, Merits, Waldemar Gerónimo Pinheiro and José Víctor dos Santos, Paraguay, December 27, 2002, para. 76. 124 IACHR, Report No. 111/10, Case 12.539, Merits, Sebastián Claus Furlan and Family, Argentina, October 21, 2010, para. 100. 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, para. 164. 29