-112recognized by the Convention to all those subject to their jurisdiction (Article 1(1)).228 170. The Court has confirmed that, in relation to the facts of this case, criminal proceedings were opened in the military and the ordinary criminal jurisdictions, and that there were also administrative and disciplinary proceedings. Consequently, in this chapter, the Court will examine the due diligence in the conduct of these official actions to investigate the facts, as well as additional elements, in order to determine whether the procedures and proceedings were conducted respecting the right to a fair trial, within a reasonable time, and whether they constituted an effective recourse to ensure the rights of access to justice, to the truth about the facts and to the reparation of the next of kin. 171. Regarding reasonable time, this Court has indicated that the right of access to justice is not exhausted with the filing of domestic proceedings, but must also ensure, within a reasonable time, the right of the alleged victims or their next of kin for every necessary measure to be taken to know the truth about what happened and to sanction those who are eventually found to be responsible.229 With regard to the principle of a reasonable time established in Article 8(1) of the American Convention, the Court has established that it is necessary to take into account three elements in order to determine the reasonableness of the time in which the proceedings are held: (a) the complexity of the case; (b) the procedural activity of the party concerned, and (c) the conduct of the judicial authorities.230 However, the pertinence of applying these three criteria to determine the reasonableness of the time of the proceedings depends on the circumstances of each case.231 Indeed, in view of the characteristics of this case, the Court will examine the reasonableness of the duration of each of the proceedings, when this is possible and pertinent. Ordinary criminal jurisdiction 172. It has been established that several criminal courts of first instance and public order courts undertook investigations and “preliminary measures” with regard to the facts of the case (supra paras. 95(56) to 95(83)). 173. In the first place, in the context of this investigation, it is evident that there was a failure to use appropriate techniques for the recovery of the remains at the scene of the crime during the exhumation procedures on the “Las Tangas” and “Jaraguay” ranches, conducted based on information provided by the confessed member of the paramilitary group, Rogelio de Jesús Escobar Mejía (supra paras. 95(70) to 95(74)). 228 Cf. Case of Palamara Iribarne, supra note 11, para. 163; Case of the Moiwana Community, supra note 7, para. 142, and the Serrano Cruz Sisters case, supra note 214, para. 76. 229 Cf. Case of the “Mapiripán Massacre”, supra note 7, para. 216; Case of the Serrano Cruz Sisters, supra note 214, para. 66, and Case of the 19 Merchants, supra note 192, para. 188. 230 Cf. Case of García Asto and Ramírez Rojas, supra note 10, para. 166; Case of the “Mapiripán Massacre”, supra note 7, para. 217, and Case of the Moiwana Community, supra note 7, para. 160. Likewise 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. 231 Cf. Case of the “Mapiripán Massacre”, supra note 7, para. 214. Likewise, Case of García Asto and Ramírez Rojas, supra note 10, para. 167.