Argentine Confederation
The fall of Rosas in 1852 allowed Gutiérrez to return to Argentina, where he attended the Constitutional Convention of 1853 as a supporter of the San Nicolás Agreement. As minister of foreign relations of the Argentine Confederation under Justo José de Urquiza, he contributed to the success of the San José de Flores Agreement in 1859, which reunited Buenos Aires and the provinces of the Argentine Confederation.