though the ICourtHR has declared a specific violation, this has not been an obstacle to consider it pertinent to establish other implications of the State’s international responsibility and, at times, to declare additional or complementary violations.132 This was justified in the instant case, taking into account the “abrupt” nature of the termination of the titular judges of the main high courts of Ecuador and the dramatic impairment of the institutional aspect of judicial independence that was declared in the Judgment; hence, I consider that the Inter-American Court should not have avoided responding to the said allegations regarding due process under the Convention in the impeachment proceedings against the judges. 102. The need for thoroughness in the arguments, for example on the different components of the victims’ right of defense in the impeachment proceedings, would have been particularly relevant, because it was highly probable that it would culminate in the autonomous declaration of the violation of the rights considered in themselves. Moreover, it should not be forgotten that the right to due process of law is, in fact, constituted by a series of inseparable and essential elements, 133 so that it is not respected unless they are all satisfied, in an integral manner. Thus, the examination of the other judicial guarantees, which it was alleged had been violated, would eventually have established more robust standards of protection for judge, justices or magistrates, subjected to impeachment by congresses, which those congresses should never consider that they are exempt from complying with. IX. DISSENT: THE NEED TO ANALYZE AND TO DECLARE THE AUTONOMOUS VIOLATION OF THE PRINCIPLE OF LEGALITY (ARTICLES 9 AND 1(1) OF THE AMERICAN CONVENTION) A) Introduction and difference with the case of the Supreme Court of Justice (Quintana Coello et al.) v. Ecuador 103. As I stated at the start of this opinion, I dissent from the majority opinion with regard to the seventh operative paragraph of the Judgment.134 Indeed, I consider that the Inter-American Court should have made a specific analysis of the arguments concerning the violation of the principle of legality established in Article 9 of the American Convention, and have declared that, in this case, the said right was violated autonomously to the detriment of the eight victims. 132 In the Case of Kimel the ICourtHR included considerations of the proportionality of the restriction to the victim’s freedom of expression. Even though, based strictly on the analysis of legality the Inter-American Court declared the respective violation, it included an analysis of the other components of the considerations on proportionality. Cf. Case of Kimel v. Argentina. Merits, reparations and costs. Judgment of May 2, 2008 Series C No. 177, paras. 81 to 94. In addition, in the Case of the Pueblo Bello Massacre, even though the ICourtHR indicated the lack of competence of the military criminal jurisdiction to examine the facts, it analyzed how, during the intervention of this jurisdiction, the investigation was not conducted with due diligence. The Inter-American Court indicated that the “limited investigative measures, and also the speed with which they were carried out, reveal little or no interest of the military criminal jurisdiction in conducting a serious and exhaustive investigation into the events that had occurred.” It is worth emphasizing that the ICourtHR also examined the effectiveness of the intervention of other systems of justice, such as the disciplinary jurisdiction. Cf. Case of the Pueblo Bello Massacre v. Colombia. Judgment of January 31, 2006. Series C No. 140, paras. 192 to 204. 133 Cf. García Ramírez, Sergio, El debido proceso. Criterios de la jurisprudencia interamericana, Mexico, Porrúa, 2012, p. 23. 134 “7. It is not required to make a ruling on the alleged violation of Article 9 of the American Convention on Human Rights, in the terms of paragraphs ¡Error! No se encuentra el origen de la referencia. and ¡Error! No se encuentra el origen de la referencia. of this Judgment. 28