-26that, during this period, the criminal proceedings were closed from September 11, 1995 to January 21, 2003, a period of more than seven years and four months. 100. Although it is true that the Court should generally consider the global length of a proceedings in order to analyze its reasonable time, in certain special situations it may be relevant to specifically examine its different stages.117 For that analysis, the different phases of the proceedings may be distinguished, which correspond to the different periods of the proceedings against Sgt. Evangelista Pinedo. 101. The first period, from November 2, 1994 to September 11, 1995, is the period from the lodging of the criminal complaint to the closing of the case. The second period, from September 11, 1995 to January 21, 2003, is when the case was archived. This phase includes the period of one year and nine months between the request of removal from the archive in 2002 and the reopening of the case in 2003. Finally, the third is from January 21, 2003 to January 6, 2011, between the reopening of the case and the payment by the State of reparations in compliance with the judgment. 102. The Court reiterates its jurisprudence that the lack of reasonableness in the time to conduct an investigation or a trial, per se, constitutes, in principle, a violation of judicial guarantees. The Court has consistently taken into account four elements in determining the reasonableness of the period: i) the complexity of the matter; ii) the procedural activity of the interested party; iii) the conduct of the judicial authorities, and iv) the harm caused to the legal situation of the person involved in the proceedings.118 103. With respect to the complexity of the case, the Court notes that the present case is not complex. It also notes that the criminal proceedings against the perpetrator of the incident do not involve complex legal aspects or discussions that could justify a delay of approximately 14 years. The Court especially takes note that Sgt. Evangelista Pinedo admitted his guilt on the day following the incident; there are witnesses who concur in their versions of what occurred, and there is no evidence that offers complexities. 104. As to the procedural activity of the interested parties, the Court notes that the arguments and the evidence show that they did not delay the proceedings and that they had only intervened when relevant. More specifically, the Court notes that the interested parties asked to be civil complainants in the process; the failure to apply the amnesty law; the reopening of the trial; the annulment of the sentence with respect to the civil redress, and, on various occasions, the reiteration of the arrest warrant of the accused. 105. With respect to the third element, the Court’s analysis may be found in the paragraphs that follow (infra paras. 106 to 121). At to the fourth element -the degree of potential harm to the legal situation of the individuals involved in the proceedings- the Court considers that the Commission and the representatives did not present evidence that would allow a conclusion on whether there was relevant harm to the legal situation of the persons or provide reasons to imply that a special acceleration should have been given to the proceedings. 106. With respect to the conduct of the judicial authorities, the Court notes that the evidence demonstrates that various aspects could have influenced the length of the criminal committal proceedings: i) those related to the opening of the committal proceedings; ii) those Cf. Case of the Afro-descendent Communities displaced from the Cacarica River Basin (Operation Genesis) v. Colombia. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 20, 2013. Series C No. 270, para. 403. See also, European Court of Human Rights. Case of Bunkate v. The Netherlands (N° 13645/88). Judgment of May 26,1993, paras. 20 to 23 and Case of Pugliese v. Italy (N. 2) (N° 11.671/85). Judgment of May 24, 1991, para. 19. 117 Cf. Case of Valle Jaramillo et al. v. Colombia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C No. 192, para. 155 and Case of Landaeta Mejías Brothers et al. v. Venezuela. Preliminary Objections, Merits, Reparations and Costs. Judgment of August 27, 2014. Series C No. 281, para. 246. 118

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