Doctrina, Revista 80

Revisión de las normas técnico registrales: ¿actualización o reformulación?

XI Congreso Nacional – Mesa de debate

El presente trabajo se trata de un extracto de la charla introductoria al debate sobre el futuro de las normas técnico registrales, dada en el XI Congreso Nacional de Encargados de Registros organizado por AAERPA.

 La idea que nos convoca hoy es trabajar sobre la disyuntiva que plantea el título y tratar de encontrar conceptos y fundamentos que nos ayuden a resolver la cuestión.

No tengo tendencia a dejarme llevar por las primeras ideas que se me crucen. Es por esto que, llegada a mí la idea que es tiempo de trabajar a fondo sobre las normas, tuve que pensar en los motivos que podrían haberme llevado a esta conclusión.

¿Por qué aquí y nosotros? La Asociación hace muchos años que ha iniciado un camino de permanente compromiso con la actividad, no sólo en la atención de los encargados, sino promoviendo los cambios que hemos sentido necesarios.

Hace ya tanto tiempo que empezamos con los cursos para mandatarios, con el fin de quitar a nuestras normas esa pátina de ciencia oculta. La ignorancia del mandatario era fuente de poder pero a la vez era una rémora en nuestro crecimiento. Luego vinieron los congresos, los cursos, la diplomatura y los cursos de capacitación continua. También fue iniciativa que nació en un congreso de AAERPA lo que luego se plasmó en la Resolución 12/97 de exámenes para acceder al cargo y, por último, los concursos para acceder al cargo donde nuestra Asociación fue parte natural e irreemplazable en los distintos tribunales evaluadores. No cabe duda, entonces, que es parte de la actividad y actitud natural de nuestra Asociación el involucrarse en todos los procesos que hacen al mejor desempeño de la actividad. Y sin duda que no hay mejor marco para debatir esos cambios que el de nuestros congresos.

LOS MOTIVOS

 1 – Necesidad de rever las normas

Ante todo debemos señalar que el Digesto, como norma única, es decir como unidad normativa, ha quedado desactualizado en cuanto a su contenido. Hay muchas normas, de suma importancia que no están incorporadas (Normas de la UIF, certificados electrónicos, normas sobre clásicos, requisitos para el cambio de uso en una CANJ). Es decir, ya hay una tarea previa a realizar que consiste en incorporar, con control de lo sistemático, muchas normas. Pero, además, estas normas a ser incorporadas también requieren de control y actualización (sobran, por ejemplo, las normas sobre subastados Ley 22.130).

Pero, además, si esta evaluación admite otro “además”, las normas del Digesto ya están bastante desactualizadas de por sí. O sea, antes de la incorporación de las nuevas normas es necesaria una revisión a fondo de todo el Digesto. Nótese, a modo de ejemplo, que las normas sobre transferencia siguen haciendo referencia a la inscripción inmediata del art. 9 cuando hay deuda de patentes. En ningún convenio del país se planteó nunca esta posibilidad.

También requieren una profunda revisión y modificación las normas sobre Tipo, Uso y destino. Las normas sobre Cambio de tipo, Alta y Cambio de Carrocería, actualización de las normas sobre Inscripción Inicial, etc. No voy a abundar en mayores consideraciones, pero esto sólo me bastó para entender que es necesario escribir de nuevo buena parte del Digesto. Y si esto fuere así, ¿será tiempo de repensar toda su estructura?

 2 – Los encargados

Cuando se piensa un una norma de este tipo, es decir un reglamento que rige una determinada actividad, se tienen en cuenta varios aspectos, entre los que se destacan: Los resultados que se quieren obtener y, sobre todo, aquellos que las deben aplicar; y aquí aparece otro de los elementos que debo traer a consideración y es la actual condición de los encargados de Registro.

Desde fines del siglo pasado no hay designaciones salvo contadas excepciones, por lo que todos acumulan una experiencia de al menos 15 años en la función. Las nuevas designaciones llegarán seguramente por medio de un concurso que garantizará la capacitación y aptitud para el cargo de los nuevos titulares. La mayoría de estos encargados han participado en los cursos y diplomaturas que ha organizado AAERPA, en los cuales se ha capacitado especialmente para la función, no sólo desde lo jurídico sino también desde lo administrativo y en las relaciones personales. Esto nos permite hablar de funcionarios especializados en la tarea a realizar. Como se puede ver con facilidad, esta realidad es muy distinta a aquella que generó la normativa que hoy ponemos en debate.

3 – Las comunicaciones

En el año 1993, cuando se dictó el primer Digesto, faltaban todavía 2 años para las primeras conexiones comerciales a Internet en nuestro país. Sólo había telefonía celular en la Ciudad de Buenos Aires, con una sola operadora (Movicom). No hace falta que describa el cambio que tenemos al día de hoy. Esto también facilita el acceso de los usuarios tanto a las normas como a las autoridades.

4 – la informática en los Registros

La actualidad en este campo ha generado un sistema donde buena parte de lo actuado por cada Registro es pasible de ser controlado on-line. Esto facilita los controles y la autoridad de control cuenta con una herramienta totalmente novedosa, que debe ser aprovechada en cuanto a la auditoría de la actividad registral.

5 – Por qué nosotros

Debemos asumir, definitivamente, el rol que nos corresponde. Somos el elemento permanente del sistema, somos los que lo llevamos a cabo. Tenemos la responsabilidad de aportar nuestra experiencia. El crecimiento sólo se puede dar con el trabajo mancomunado de autoridades y encargados. Tenemos que levantar la mirada y asumir la parte que nos toca en la mejora del sistema.

LAS VENTAJAS DE LA SIMPLIFICACIÓN PROPUESTA

1 – Resolver de acuerdo con las normas generales

Desde el punto de vista de los encargados, la simplificación de las normas implica una ventaja por un lado y una carga por otro. No hay ninguna duda que muchas veces los encargados vacilan en la resolución de determinada situación, más que por dudar de los caminos jurídicos para ello que por temor a que haya alguna disposición, circular, dictamen etc. que proponga algo distinto a lo pensado. Esto trae como resultado cierta parálisis y muchas veces la necesidad de una consulta. ¿Cuántas veces les pasa que la duda para resolver alguna cuestión no está en las consecuencias de sus actos sino en lo que podrán opinar los inspectores?

2 – Resolver el caso concreto

Como contrapartida, esto también nos elimina lo fácil que puede resultar atenerse a lo taxativo de una norma, a pedir determinados requisitos tan solo porque lo dice el Digesto. Nos obligará a leer, a estudiar y a resolver con fundamento en cada caso. Hemos cedido una tarea central de nuestra razón de ser, cual es la calificación registral, a favor de quien dicta las normas.

3 – Mejorar la tarea de auditoría

En cuanto a la autoridad de control, la eliminación de normas superfluas simplificará las tareas de auditoría, eliminando lo superficial y permitiendo ocuparse de lo relevante. Eliminará una enorme cantidad de consultas y pedidos de dictamen que, a decir de los involucrados, ha sido la mayor carga de trabajo que tiene o ha tenido el Departamento Normativo.

Hemos visto auditorías donde se invierten tiempo y esfuerzo en controlar si se ha anotado la cancelación de prenda en la copia no negociable, si se ha consignado en la hoja de registro la valuación tenida en cuenta para el cobro de un sellado aún con el sistema el 13 S, si se ha dejado constancia de la negativa de pago de infracciones, si el Registro sin afectar en nada su servicio estuvo “un rato” por debajo del stock de títulos, etc. Todo ello tan solo porque “hay una disposición o circular que así lo indica”. También los inspectores han perdido su capacidad de análisis, para aplicar sin ningún tipo de evaluación circunstancial normas obsoletas y muchas veces inconducentes. Esa tarea también debe recobrar jerarquía.

LA PROPUESTA

He revisado las normas de otros organismos similares, como el Registro de Aeronaves o el Registro Inmueble, y la característica en común es que son normas dirigidas al usuario y no al funcionario. Es decir que se indican los requisitos de cada trámite. El acto registral se rige por normas generales, por principios aplicables a todo el derecho registral, y las cuestiones meramente procedimentales quedan reservadas al criterio del registrador o a instrucciones generales. No olvidemos que nuestra actividad cuenta también con el R.I.N.O.F.

Transferencia

Como corolario y a simple modo de ejemplo, propongo una idea de los aspectos centrales que debiera tener la norma sobre transferencia de dominio, para plasmar mi visión de la cuestión:

La transferencia de dominio se peticionará mediante la S.T. 08. Las firmas de las partes deberán estar certificadas, en las formas establecidas en Tít. xx, Cap. xx. Y en caso de corresponder deberá contarse con el asentimiento conyugal (Tít. xx, Cap. xx). El domicilio del adquirente se deberá acreditar de acuerdo a lo establecido en Tít. xx, Cap. xx.

Se deberá presentar el título de propiedad y exhibir la cédula, que podrá ser entregada al concluir el trámite.

 Además, en los casos que corresponda:

1) Presentar Verificación Física (Tít. Xx, Cap. xx).

2) Cumplir con las normas de orden nacional que correspondan de acuerdo a lo normado en el Tít. xx, Cap. xx. (CETA, UIF, etc.).

3) Cumplir con el impuesto de sellos que corresponda según la jurisdicción.

4) Comunicación al acreedor prendario.

5) En caso que el dominio se encuentre embargado, el adquirente deberá asumir la deuda. Luego habrá una Sección con los requisitos propios de los casos especiales.

CASOS ESPECIALES

Sucesión.

Escritura pública.

Subasta art. 39, Ley de Prenda.

Por orden judicial.

Subasta de automotores oficiales.

Comerciantes habitualistas.

Transferencia de dominio fiduciario.

Estos son los lineamientos básicos de mi propuesta. Creo que amerita un debate, ya que necesariamente tiene como antecedente, pero también como consecuencia, un salto de calidad en nuestro trabajo. Asumiremos nuevas responsabilidades que la libertad de decisión conlleva. Quiero, entonces, saber vuestra opinión para luego decidir si nuestra Asociación debe promover este cambio profundo en las normas que rigen la actividad.

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