Several cases of grave breaches of the Geneva Conventions have been prosecuted by Spanish courts according to universal jurisdiction principle. However, while it was being reformed Article 23.4 of the Spanish Organic Law on the Judiciary, it was denounced before the Audiencia Nacional, war crimes committed by Burmese Military Junta. Although the case was rejected due to the lack of connections to Spanish interests, ignoring customary international humanitarian law, it remains unanswered by the Spanish Supreme Court and Constitutional Court, if Spanish jurisdiction can enforce individual criminal responsibilities for the commission of war crimes in the context of internal armed conflicts