82 every necessary step taken to know the truth and punish those responsible for the events.121 Certainly the Court has established, regarding the reasonable time principle set out in Article 8(1) of the American Convention, that three aspects must be taken into account to determine the reasonableness of the time within which a case is carried out. (a) the complexity of the matter, (b) the procedural activities carried out by the interested party, and (c) the conduct of judicial authorities.122 However, the appropriateness of applying these criteria to determine the reasonableness of the length of a proceeding depends of the circumstances of each case.123 Furthermore, in such cases, the State’s duty to wholly serve the purposes of justice prevails over the guarantee of reasonable time. As regards the new investigations and prosecutions carried out since the start of the transition, even though the matter is clearly complex due to the nature of the events, the number of victims and defendants and the delays caused by them, they cannot be considered as separate from the earlier period. The obstruction of the proceedings has led investigations and prosecutions to last over 14 years from the perpetration of the events that involved the execution or forced disappearance of the victims, which altogether has by far exceeded the term that could be considered reasonable for these purposes. 150. Regarding to the scope of these new investigations, no new proceedings were instituted in the ordinary courts concerning persons convicted by military courts as perpetrators of the crimes, save for certain acts of one person initially prosecuted by such courts. There is no showing that said sentences, which became effective again after the CSJM’s decision of 2001, have been served. Moreover, in spite of the complaint filed by the Procuraduría Ad Hoc (Ad Hoc Prosecutor’s Office) against three of the alleged instigators — to wit, Hermoza Ríos, Montesinos and Pérez Documet, who were discharged by the military courts (supra para. 80(82))—, no formal charges have been brought against them in the ordinary courts. A motion for nullity of the prosecutions conducted in the military courts filed with the CSJM by two of the victims' next of kin was dismissed in July 2004 (supra para. 80(65) and 80(66)). This means that, in a way, the proceedings in the military courts have continued to hamper the investigation and eventual trial and punishment of all those responsible in the ordinary courts. 151. In this connection, the Commission and the representatives have asserted that the State has relied on the concept of double jeopardy to avoid punishing some of the alleged instigators of these crimes; however, double jeopardy does not apply inasmuch as they were prosecuted by a court who had no jurisdiction, was not independent or impartial and failed to meet the requirements for competent jurisdiction. In addition, the State asserted that “involving other people who might be criminally liable is subject to any new conclusions reached by the Ministerio Público [General Attorney’s Office] and the Judiciary in investigating the events and meting out punishments,” and that “the military court’s decision to dismiss the case has no legal value for the General Attorney's Office's preliminary investigation. That is, the double jeopardy defense does not apply.” 121 Cf. Case of the “Mapiripan Massacre”, supra note 2, para. 216; Case of the Serrano-Cruz Sisters, supra note 98, para. 66, and Case of 19 Tradesmen, supra note 110, para. 188. 122 Cf. Case of Vargas-Areco, supra note 1, para. 102; Case of Ximenes-Lopes, supra note 6, para. 196, and Case of García-Asto and Ramírez-Rojas. Judgment of November 25, 2005. Series C No. 137, para. 166. Similarly, cf. European Court of Human Rights. Wimmer v. Germany, no. 60534/00, § 23, 24 May 2005; Panchenko v. Russia, no. 45100/98 § 129, 8 February 2005, and Todorov v. Bulgaria, no. 39832/98, § 45, 18 January 2005. 123 Cf. Case of the Pueblo Bello Massacre, supra note 3, para. 171 and Case of the “Mapiripan Massacre”, supra note 2, para. 214. Similarly, Case of García-Asto and Ramírez-Rojas, supra note 123, para. 167.