Revista 90, Sin categoría

Transferencia por liquidación de la comunidad conyugal ante el nuevo código civil y comercial ¿Se debe adecuar la normativa?

12° Congreso Nacional – Ponencia

 

I – INTRODUCCION

El nuevo Código Civil y Comercial de la Nación (CCyCN), aprobado por Ley Nº 26.994, y cuya entrada en vigencia se produjo el 1º de agosto de 2015 (conforme Ley Nº 27.077), introdujo importantes cambios en diversas áreas del Derecho.

En particular, en lo referente al Régimen Jurídico del Automotor, la Disposición D.N. Nº 353/15 ha receptado varias de dichas innovaciones, pudiendo enunciar sólo de manera ejemplificativa, lo referente al asentimiento conyugal por poder, la figura del Consorcio de Propietarios como persona jurídica, la manera de probar el carácter propio o ganancial de un bien, la inscripción inicial de dominio fiduciario, la inscripción de vehículos a nombre de sociedades no constituidas según los tipos de la Ley Nº 19.550, etc.

Los cambios en el régimen jurídico matrimonial y en el divorcio han sido estructurales, y traen un nuevo paradigma, lo que motiva la realización de la presente ponencia. Entre las principales novedades, se regulan las convenciones matrimoniales, se crea un régimen de separación de bienes, el divorcio ya no está vinculado con una causa, puede ser solicitado de manera conjunta o unilateral, siendo la voluntad de los contrayentes el único sostén del matrimonio. El nuevo Código, en esta materia, sigue la concepción de la reforma española de 2005, en cuya exposición de motivos establecía: “… se justifica reconocer mayor trascendencia a la voluntad de la persona cuando ya no desea seguir vinculado con su cónyuge. Así, el ejercicio de su derecho a no continuar casado no puede hacerse depender de la demostración de la concurrencia de causa alguna, pues la causa determinante no es más que el fin de esa voluntad expresada en su solicitud … Así pues, basta con que uno de los esposos no desee la continuación del matrimonio para que pueda demandar el divorcio, sin que el demandado pue da oponerse a la petición por motivos materiales, y sin que el Juez pueda rechazar la petición, salvo por motivos personales”.

Dentro de este nuevo paradigma, se regula de manera diferente lo relativo a la liquidación y partición de la comunidad, otorgando en cuanto a la forma, mayor amplitud a los ex cónyuges.

Motiva el presente trabajo, analizar la forma de partir la comunidad de bienes gananciales a la luz del nuevo Código Civil y Comercial de la Nación, y si esta forma genera alguna consecuencia práctica en el Régimen Jurídico del Automotor, que amerite ser regulada por el Digesto de Normas Técnico Registrales.

II – LA LIQUIDACIÓN Y PARTICIPACIÓN DE LA COMUNIDAD

  1. A) El anterior Código Civil de la Nación (CCN): Forma de partir la Sociedad Conyugal

Se define como liquidación al proceso mediante el cual se busca “establecer con precisión la composición de la masa por dividir. Para ello es necesario concluir los negocios pendientes, determinar el carácter de los bienes y fijar su valor, pagar las deudas a favor de terceros, ajustar las cuentas entre la sociedad conyugal y los cónyuges, y separar los bienes propios de cada cónyuge, para finalmente establecer el saldo partible. Todo este conjunto de operaciones es lo que configura la liquidación de la sociedad conyugal”[1]. Luego de ello, viene la partición de la comunidad de bienes gananciales.

El anterior Código Civil de la Nación (CCN) a estos procesos los llamaba liquidación y partición de sociedad conyugal, mientras que hoy se denominan liquidación y participación de la comunidad de bienes gananciales. La anterior normativa no regulaba la forma en que debía efectuarse la partición, pero la doctrina interpretaba pacíficamente que se regía por las normas de partición de las sucesiones. Ello, toda vez que cualquier remisión del anterior Código a los supuestos de disolución (v.gr. disolución por causa de muerte, contratos de sociedad en general), derivaba a las normas de las sucesiones.

La anterior normativa establecía en su artículo 3.462 del CCN -tomando lo aplicable a sucesiones- que, si todos los herederos estaban presentes y eran capaces, la partición podía hacerse en la forma y por el acto que por unanimidad juzguen convenientes. Sin embargo, esta amplitud de forma no era tal, ya que quedaba condicionada por los artículos 1.184, inciso 2[2], y 3.465 del CCN[3].

En consecuencia, y bajo la anterior norma, la partición podía ser privada o judicial. Si era privada, además de tener que ser todos los copartícipes capaces, la forma exigida no era a elección de los ex cónyuges, sino que debía ser por escritura pública o por convenio homologado judicialmente -parte de la doctrina la llamaba “mixta” a esta última modalidad- (conforme artículo 1.184, inciso 2 del CCN). Debía ser, en cambio, judicial cuando ocurrían algunos de los supuestos del artículo 3.465 del CCN.

En dicho marco, el Digesto de Normas Técnico Registrales regulaba en el Título II, Capítulo II, Sección 2ª, de manera específica (dentro de las transferencias por escritura pública), a la efectuada por liquidación de sociedad conyugal. Cuando la partición se efectuaba de manera privada por convenio homologado, o cuando se efectuaba de manera judicial, era de aplicación la Sección 4ª (transferencia ordenada por autoridad judicial) del referido cuerpo normativo.

  1. B) Nuevo Código Civil y Comercial de la Nación (CCyCN): Forma de partir la comunidad de bienes gananciales

 El artículo 500 del nuevo Código (CCyCN) regula lo relativo a la forma de partición de la comunidad, remitiendo -a diferencia del Código anterior- de manera expresa a la forma prescripta para la partición de las herencias.

El artículo 2.369 del CCyCN establece un principio similar al del derogado 3.462 del CCN, en virtud del cual, si todos los copartícipes están presentes y son capaces, la partición puede hacerse en la forma y por el acto que por unanimidad juzguen conveniente.

Esta libertad de forma, se encuentra limitada por dos artículos. Por un lado, el artículo 2.371 del CCyCN requiere la partición judicial si ocurre algunos de los siguientes casos: a) si hay copartícipes incapaces, con capacidad restringida o ausentes; b) si terceros se oponen a la partición privada; c) si los copartícipes no se ponen de acuerdo en hacer la partición privada.

Por otro lado, el artículo 1.017 del CCyCN establece que deben ser otorgados por escritura pública los contratos que tengan por objeto la adquisición, modificación o extinción de derechos reales sobre inmuebles. Nótese que no incluye a los muebles registrables -como sí expresamente lo ha previsto el artículo 1.552 del CCyCN, al requerir que el contrato de donación de muebles registrables sea por escritura-.

En consecuencia, y en el caso que los ex cónyuges se pongan de acuerdo en realizar la partición de manera privada, deberán utilizar la forma de la escritura pública en lo relativo a inmuebles, y entendemos que de tratarse de automotores u otros bienes que no sean inmuebles, ya no resultaría aplicable la exigencia de la escritura o convenio homologado, toda vez que el artículo 1.184 del CCN ha sido derogado.

Incluso, teniendo en cuenta que la partición puede ser total o parcial, entendemos que podrían los ex cónyuges realizar por escritura pública la partición de bienes inmuebles, y por otro acto privado la relativa a los restantes bienes que integran la comunidad.

Al respecto, la nueva doctrina ha dicho: “La novedad en materia de partición privada es que la forma instrumental ya no requiere la escritura pública en todos los casos. Lógicamente, esta será necesaria cuando verse sobre bienes inmuebles (art. 1.017). Ello implica que -con las críticas que inevitablemente merece del notariado- los convenios celebrados por instrumento privado deben considerarse plenamente válidos sin ninguna otra formalidad cuando no versen sobre bienes inmuebles o no se dé algún otro supuesto que imponga la escritura como formalidad”[4].

De compartirse esta interpretación, y reflexionando sobre su aplicación práctica, podría ser válido que los ex cónyuges peticionen la transmisión del dominio de un automotor como consecuencia de la liquidación y partición privada de la comunidad, presentando, por ejemplo, la Solicitud Tipo 08, junto con un testimonio o partida de matrimonio con anotación marginal -a los fines de acreditar simplemente el divorcio vincular-, y un convenio de mediación donde han realizado la partición. O incluso, y tomando un criterio más amplio, podrían simplemente firmar la Solicitud Tipo 08 como instrumentación de la manifestación de voluntad de la partición, y acompañar el testimonio de la sentencia de divorcio.

III – ¿DEBE ADECUARSE EL DIGESTO DE NORMAS TÉCNICO REGISTRALES?

Para entrar a analizar si debe adecuarse el Digesto de Normas Técnico Registrales es necesario, primero, determinar si el órgano de aplicación del Régimen Jurídico del Automotor está de acuerdo con esta interpretación.

De ser así, habría que preguntarse si un precepto del Código es aplicable de manera directa, o si requiere una regulación específica. Entendemos que no se requiere una regulación específica en el Digesto, ya que el Código opera “per se”, desde su entrada en vigencia, debiendo los encargados de Registro suplir las eventuales lagunas, teniendo en miras los principios del Régimen Jurídico, la analogía, y utilizando las distintas técnicas hermenéuticas.

Sin embargo, los actores del sistema registral estamos acostumbrados, durante los últimos años/décadas, a un exceso de regulación normativa por parte del órgano de aplicación. El Digesto, y un sinfín de disposiciones y circulares establecen al detalle todo lo atinente a la actividad registral, dejando poco margen a la decisión del registrador. Dentro de este paradigma de exceso de regulación normativa, es natural que los encargados de Registro, así como los peticionarios y presentantes de trámites, esperen una adecuación del Digesto, que contemple la registración de la partición privada de la comunidad de bienes gananciales.

De compartirse este criterio, se propone la incorporación de una nueva Sección al Título II, Capítulo II del Digesto, que podría denominarse “transferencia por partición privada de la comunidad de bienes gananciales”, que contemple la posibilidad de peticionar la adjudicación de la manera indicada en el punto precedente.

BIBLIOGRAFÍA:

BELLUSCIO, Augusto C. (dir.) y ZANNONI, Eduardo A. (coord.): Código Civil y leyes complementarias. Comentado, anotado y concordado, T. VI. Buenos Aires, Astrea, 1992.

CERNIELLO, Romina Ivana y GOICOECHEA, Néstor Daniel: Revista del Notariado del Colegio de Escribanos de la Ciudad de Buenos Aires. Revista Nº 922 (oct-dic 2015). Autores. Fecha de publicación: junio 2016.

CORNEJO, Javier Antonio: “Cuestiones Registrales del Régimen Jurídico del Automotor”. Ediciones CARCOS SRL. Mayo de 2007.

PRÓSPERI, Fernando F. y BALBO, Rodolfo Germán: “El Régimen patrimonial del matrimonio en el nuevo Código Civil y Comercial de la Nación”. Revista Ámbito Registral de AAERPA, Año XIX Nº 81, octubre de 2015.

RIVET, Helena María: “Los trámites en el Registro Nacional de la Propiedad del Automotor – Recaudos Generales”. Ediciones Ámbito Registral. Mayo de 2007.

VIGGIOLA, Lidia E. y MOLINA QUIROGA, Eduardo: “Régimen Jurídico del Automotor”. La Ley, año 2002.

[1] -Belluscio, Augusto C. (dir.) y Zannoni, Eduardo A. (coord.): Código Civil y leyes complementarias. Comentado, anotado y concordado, t. VI. Buenos Aires, Astrea, 1992, p. 240

[2] -Art. 1.184, inc. 2º del CCN: “Deben ser hechos en escritura pública, con excepción de los que fuesen celebrados en subasta pública: …Las particiones extrajudiciales de herencias, salvo que mediare convenio por instrumento privado presentado al juez de la sucesión…”.

[3] -Art. 3.465 CCN: Las particiones deben ser judiciales: 1 – Cuando haya menores, aunque estén emancipados, o incapaces, interesados, o ausentes cuya existencia sea incierta; 2 – Cuando terceros, fundándose en un interés jurídico, se opongan a que se haga partición privada; 3 – Cuando los herederos mayores y presentes no se acuerden en hacer la división privadamente.

[4] -Revista del Notariado del Colegio de Escribanos de la Ciudad de Buenos Aires. Revista Nº 922 (oct-dic 2015). Autores: CERNIELLO, Romina Ivana y GOICOECHEA, Néstor Daniel. Fecha de publicación: junio 2016.

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