Unlocking an iPhone from Movistar Spain 3G

Hi there!
I come to this forum looking for help on how to properly unlock an iPhone that was bought with the carrier Movistar in Spain.
In one month, I will have completed the 24-month subscription and I already paid the penalty to clear it in advance, which means I have no subscription whatsoever for this terminal right now.
I have asked Movistar to start the process of unlocking, which is recommended by Spanish Communication Market Commission in its report from April 15th 1999 (https://ov.aytojaen.es/portal/RecursosWeb/DOCUMENTOS/1/0_2346_1.pdf): It is necessary that the terminal may be unlocked freely, once the necessary time has passed to comply with the subsidize cost, so it has been recovered in the concept of telephone consumption or, in the contrary, by paying the subsidize cost that is left to be recovered.
I have called my carrier, Movistar, and they say this is an exclusive terminal by Movistar and they will not unlock it.
Can they do this? Can anyone help me on that here?
I believe the only thing left I have is to place a claim and, if necessary, take the necessary legal actions...
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