This is a thesis in the field of Comparative Political Communication, which is also articulated with the studies of media and democracy. More specifically, it proposes a comparative model of analysis to political communication, focusing on the relationship between media and democracy in Latin America. In broader terms, the methodology developed helps to broaden the understanding of political communication phenomena, in the countries of the continent, in the context of their particular democratic reality. As it is a theoretical study, it is intended for application in future case studies. The perspective assumed in this work is an alternative to the rationalist tradition, in its functionalist inclinations (based on cause and effect relations), which nourish a considerable part of the field s reflections. It develops, based on a review of these foundations, a framework informed by another epistemology, closer to Critical Theory, constructivism and hermeneutics, which emphasizes interdependence and recursion as important analysis guidelines. Thus, it discusses the logic of the effects of communication and politics on life in society and privileges, instead, the understanding of how such phenomena affect and are affected by social dynamics. In essence, the model is thinking in terms of a context of political communication (formed by the socio-cultural, political and media environments) in which the practical phenomena of political communication occur. Therefore, it goes beyond the dimension of structures and institutions, to also incorporate practices (political communication per se) - bringing relief (still) to the public, often neglected by gender studies (communication) compared policy).