44 94. It has also been proved that on July 11, 1997, “Directorial Resolution” No. 117-97-IN-050100000000, signed by the Director General of Migration and Naturalization, annulled this nationality title, stating that there had been “substantial omissions that invalidate[d] it [ipso jure], because the required, prior renunciation of his nationality before the competent Peruvian authorities had not been confirmed, and it had not been confirmed in writing that he had done so before his country of origin”82. 95. From the foregoing, it is evident that Mr. Ivcher did not expressly renounce his nationality, which is the only way of losing it, according to the Peruvian Constitution, but was deprived of it when his nationality title, without which he was unable to exercise his rights as a Peruvian national, was annulled. Moreover, the procedure used to annul the nationality title did not comply with the provisions of domestic legislation, because, according to Article 110 of Peru’s Law on General Norms of Administrative Procedures, a nationality title may only be annulled within the six months following the date on which it was acquired (infra para. 109). Since this certificate was annulled in July 1997, 13 years after it had been granted, the State failed to comply with the provisions of its domestic legislation and arbitrarily deprived Mr. Ivcher of his nationality, violating Article 20(3) of the Convention. 96. Furthermore, the authorities who annulled Mr. Ivcher’s nationality title did not have competence. As it has been established (supra para. 76.a), Mr. Ivcher Bronstein acquired Peruvian nationality through a “supreme resolution” of the President, and his nationality title was signed by the Minister for Foreign Affairs; however, he lost his nationality as the result of a “‘directorial resolution’ of the Migration and Naturalization Directorate”, which is undoubtedly of a lower rank than the authority that granted the corresponding right (supra para. 76.q), and, consequently, could not deprive the act of a superior of its effects. Once again, this demonstrates the arbitrary character of the revocation of Mr. Ivcher’s nationality, in violation of Article 20(3) de the American Convention. 97. In view of the foregoing, the Court concludes that the State violated the right to nationality embodied in Article 20(1) and 20(3) of the American Convention, with regard to Baruch Ivcher Bronstein. XI VIOLATION OF ARTICLE 8 (JUDICIAL GUARANTEES) The Commission’s arguments 98. With regard to Article 8 of the Convention, the Commission alleges that: a) the right to due process or the “right to a procedural defense” is a guarantee applicable to all types of judicial or administrative procedures that involve the determination of a right and is fundamental to the rule of law; 82 Cf. Simple copy of the “Directorial Order” No. 117-97-IN-050100000000, of July 11, 1997, headed: Peruvian nationality title annulled, published in the official gazette El Peruano.