114 after the two-year time limit established by Colombian law, and that of Graciela Arboleda Rodríguez, because the minimum documentation required was not presented. The Court’s findings 283. Article 8(1) of the American Convention establishes: Every person has the right to a hearing, with due guarantees and within a reasonable time, by a competent, independent, and impartial tribunal, previously established by law, in the substantiation of any accusation of a criminal nature made against him or for the determination of his rights and obligations of a civil, labor, fiscal, or any other nature. 284. Article 25 of the Convention stipulates: 1. Everyone has the right to simple and prompt recourse, or any other effective recourse, to a competent court or tribunal for protection against acts that violate his fundamental rights recognized by the constitution or laws of the state concerned or by this Convention, even though such violation may have been committed by persons acting in the course of their official duties. 2. The States Parties undertake: a. to ensure that any person claiming such remedy shall have his rights determined by the competent authority provided for by the legal system of the state; b. to develop the possibilities of judicial remedy; and c. to ensure that the competent authorities shall enforce such remedies when granted. 285. During the processing of this case before the Court, the State asserted that it had not violated Articles 8(1) and 25 of the Convention. It argued that the domestic remedies should be assessed integrally, because it is the criminal, administrative and disciplinary proceedings that have jointly and effectively achieved the results to date. The Commission and the representatives affirmed that the State has violated these articles for a number of reasons that include the flawed and incomplete investigations, the time that the proceedings have taken, and the latter’s lack of effectiveness and results, all of which have led to the partial impunity of those responsible for the massacres of La Granja and El Aro. 286. In continuation, the Court will refer, first, to considerations applicable to the facts of the La Granja and El Aro cases in relation to the obligations established in Articles 8(1) and 25 of the Convention. Then, in separate sections, it will examine the respective criminal, administrative and disciplinary proceedings, indicating in each case the findings applicable to the investigations carried out into both events, and also the specific findings in each case. 287. The Court has affirmed that, under the American Convention, the States Parties are obliged to provide effective judicial remedies to the victims of human rights violations (Article 25), remedies that must be implemented according to the rules of due process of law (Article 8(1)), all within the general obligation of States to ensure to all persons subject to their jurisdiction free and full exercise of the rights established in the Convention (Article 1(1)).232 232 Cf. Case of Baldeón García, supra note 5, para. 143; López Álvarez case. Judgment of February 1, 2006. Series C No. 141, para. 147; and Case of the Pueblo Bello Massacre, supra note 9, para. 169.