should be considered along with the interests at stake.194 The Commission considers that in cases of alleged disappearance the passage of time is especially important to the situation of the victim, as the way in which the danger to their life and wellbeing materializes may hinge on a prompt and efficient state response. 147. The Commission believes that the almost 15 years that have elapsed since the report was filed constitute an excessively long time that has not been justified by the State. Therefore, the Commission finds that the State violated the reasonable-time rule. iv) Conclusion 148. In accordance with previous sections, the Commission considers that the State of Guatemala breached its duty of due diligence throughout the investigation. Likewise, the IACHR concludes that the facts reflect affirmative efforts to deflect the investigation, which prevented proper monitoring and effective logical lines of inquiry in order to clarify the facts, identify the whereabouts of Mrs. Gutierrez and punish the persons responsible, and involved the loss of evidence and opportunities to advance the investigation. The Commission also considers that the process does not comply with the guarantee of reasonable time. 149. Based on the foregoing, the Commission concludes that the Guatemalan State violated the rights to a fair trial and judicial protection recognized in Articles 8(1) and 25 of the American Convention taken in conjunction with the obligations set forth in Article 1(1) thereof, to the detriment of Mayra Angelina Gutiérrez and her family, namely, her daughter Ángela María del Carmen Argüello Gutiérrez, her sisters Ángela and Nilda Gutiérrez, and her brother Armando Gutiérrez. The Commission also considers that the Guatemalan State violated Article I(b) of the Inter-American Convention on Forced Disappearance of Persons to the detriment of Mayra Angelina Gutiérrez and her family, namely, her daughter Ángela María del Carmen Argüello Gutiérrez, her sisters Ángela and Nilda Gutiérrez, and her brother Armando Gutiérrez. 2. Right to a fair trial and judicial protection and the principle of equal protection and nondiscrimination (Articles 8(1), 24, and 1(1) of the American Convention) 150. Article 24 of the Convention provides: All persons are equal before the law. Consequently, they are entitled, without discrimination, to equal protection of the law. 151. The Court has stressed that investigations of cases involving possible acts of violence against women should be conducted with a gender-aware approach.195 The Commission recalls what its report entitled “Access to Justice for Women Victims of Violence in the Americas” says, in the sense that [t]he influence exerted by discriminatory socio-cultural patterns may cause a victim’s credibility to be questioned in cases involving violence, or lead to a tacit assumption that she is somehow to blame for what happened, whether because of her manner of dress, her occupation, her sexual conduct, relationship or kinship to the assailant and so on. The result is that prosecutors, police and judges fail to take action on complaints of violence. These biased discriminatory patterns can also exert a negative influence on the investigation of such cases and the subsequent weighing of the evidence, where stereotypes about how women should conduct themselves in interpersonal relations can become a factor.196 194 I/A Court H.R., Case of Garibaldi v. Brazil, Preliminary Objections, Merits, Reparations and Costs. Judgment of September 23, 2009. Series C No. 203, par. 138; Case of Valle Jaramillo et al. v. Colombia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 192, par. 155; and Case of Kawas Fernández v. Honduras. Merits, Reparations and Costs. Judgment of April 3, 2009 Series C No. 196, par. 115. 195 I/A Court H.R., Case of Veliz Franco et al. v. Guatemala. Preliminary Objections, Merits, Reparations and Costs. Judgment of May 19, 2014. Series C No. 277, par. 216. 196 IACHR, Access to Justice for Women Victims of Violence in the Americas, OEA/Ser.L/V/II. Doc. 68, January 20, 2007 (Annexes to the petition, Volume VII, Annex 2, page 1822). 31