Doctrina, Revista 104

La cesión de factura de un vehículo 0 km – Análisis normativo y propuestas

Actualmente, la posibilidad de ceder la posición contractual derivada de una factura de compraventa de un vehículo 0 km no se encuentra regulada en el menú de trámites tipificados en el Digesto de Normas Técnico-Registrales. Sin embargo, los usos y costumbres comerciales fueron admitiendo esta “praxis”, por lo que urge la necesidad de encontrar una solución normativa adecuada y unánime en los distintos Registros Seccionales de la Propiedad del Automotor.

Por aplicación del principio de legalidad, considero que la cesión de los derechos emergentes de una factura debe ser encuadra a la luz de las normas contenidas en el Código Civil y Comercial de la Nación, en cuanto tronco o raíz originaria donde se funda el derecho común para todo el territorio argentino. Y en este camino, el registrador no debe calificar estos acuerdos como una transmisión de la propiedad del vehículo ni exigir la forma solemne de la escritura pública, ya que no se trata de una donación. Por el contrario, este tipo de negocio jurídico debería ser subsumido en el marco jurídico previsto para la cesión de la posición contractual, por lo que sería exigible cumplir la forma escrita y la conformidad del cedido para que sea plenamente eficaz y oponible a terceros.

Introducción

El presente trabajo tiene por objeto analizar el contrato de cesión de la posición contractual emergente de la compraventa de un vehículo 0 km desde una perspectiva dialógica entre el marco normativo del Código Civil y Comercial de la Nación, en tanto derecho común y subsidiario, y el Régimen Jurídico del Automotor, en cuanto legislación específica y diferenciada para este tipo de bienes. Para llevar adelante este propósito, el estudio se divide en tres secciones principales.

En la primera, abordo las notas específicas del carácter constitutivo del Registro Nacional de la Propiedad del Automotor y los alcances de la inscripción inicial, señalando sus principales rasgos distintivos.

Posteriormente, en el segundo segmento bosquejo, brevemente, algunas nociones sobre la función calificadora del registrador

para luego introducirme en el contrato de cesión de la posición contractual resultante de una factura de compraventa, a los efectos de describir su definición legal, partes, objetos, forma y efectos jurídicos, entre otras particularidades.

Por último, en la tercera parte planteo algunas reflexiones finales a modo de cierre y conclusión personal, donde resalto la importancia de arribar a una norma específica para regular la posibilidad de esta cesión. Con esta herramienta normativa, lograríamos una respuesta uniforme y coherente en los distintos Registros Seccionales de la Propiedad del Automotor, distribuidos a lo largo y ancho del país.

I- Primera Parte: El carácter constitutivo del Registro Nacional de la Propiedad del Automotor

Los automotores -y las relaciones jurídicas derivadas de ellos- no tuvieron una regulación propia en la codificación civil y comercial del siglo XIX, debido a que este medio de transporte todavía se encontraba en su etapa embrionaria. Reparemos en el hecho que el primer automóvil que ingresó a nuestro país fue un “Daimler”, un triciclo a vapor importado por Dalmiro Varela Castex en 1879, es decir, casi diez años después de redactada nuestra legislación civil y comercial. Y, en 1895, Varela Castex introdujo el Benz, que se constituyó en el primer vehículo oficialmente patentado en la ciudad de Buenos Aires[i].

En el Código Civil decimonónico, el principio rector estaba regulado en el art. 2.412 (similar al art. 2.279 del Código Civil francés), que consagra la regla que “en materia de muebles la posesión vale título” (“en fait de meubles la possessión vaut titre”), siempre que la cosa no sea hurtada o perdida. No obstante, a medida que el uso de este vehículo adquirió notoriedad, primero como objeto de lujo y posteriormente como medio de transporte o herramienta de trabajo, se tornó evidente la insuficiencia de las normas reguladas respecto de las cosas muebles en general.

Así, con la finalidad de identificar posibles hechos delictivos y posibilitar su libre circulación económica, en el año 1958 el Poder Ejecutivo Nacional dictó el Decreto-Ley N° 6.582, en adelante Régimen Jurídico del Automotor (R.J.A.), en virtud del cual se crea el Registro Nacional de la Propiedad Automotor y le otorga carácter constitutivo, en el sentido de que el primer adquirente recién se convierte en “dominus” de la cosa con la inscripción registral.

El mencionado rasgo constitutivo se encuentra plasmado en el propio art. 1° del R.J.A., que reza: “la transmisión del dominio de los automotores sólo producirá efectos entre las partes y con relación a terceros, desde la fecha de su inscripción en el Registro Nacional de la Propiedad del Automotor”.

A partir de la puesta en vigencia del R.J.A., para llegar a ser dueño de un automotor no se exige la entrega del vehículo ni que se ejerzan actos materiales sobre él, ya que el propio Estado remplazó la tradición por la inscripción como modo suficiente para adquirir la propiedad en esta clase de bienes. La naturaleza constitutiva de la registración de automotores implica que ella no sólo hace oponible el derecho real de propiedad frente a terceros, como sucede en materia de bienes inmuebles, sino que recién a partir de la inscripción nace el derecho real, aun incluso entre las partes[ii].

Recordemos brevemente que los registros constitutivos son aquellos en los que el derecho real se constituye o transmite dentro del Registro, entendiendo por ello que la función registral, en estos casos, es esencialmente doble: por un lado, interviene estructuralmente en la constitución o transmisión del derecho real, otorgando al adquirente el título de dominio; por otro lado, asume la función publicitaria que es propia de todo Registro.

El aspecto constitutivo de la inscripción registral adquiere una importancia fundamental en función de preservar los valores de seguridad y certeza jurídica, ya que permite conocer a ciencia cierta quién es el titular del automotor en cuestión. Este asunto es sumamente valioso para prevenir posibles hechos delictivos y salvaguardar el patrimonio de los ciudadanos, razones que justifican que el Estado haya tomado a su cargo la tarea de registrar estos bienes como

una forma de garantizar la incolumidad del derecho de propiedad y el pleno goce del derecho a la libertad comercial.

Una vez que el vehículo se inscribe en el Registro Nacional de la Propiedad del Automotor adquiere un nuevo estatus legal, ya que se convierte en una cosa mueble registrable, sometida a un plexo jurídico especial. Antes de la inscripción inicial, el vehículo no se encuentra en condiciones de circular por la vía pública, sino que sólo se halla en condiciones de ser comercializado por el fabricante, empresa terminal, comprador declarado en despacho o sus concesionarios oficiales.

En consecuencia, el R.J.A. considera, para todos los efectos registrales, como primera transferencia aquella que se inscribe en forma inicial en el Registro, y que tiene por transmitente a la empresa terminal, fabricante, importador o sus concesionarios oficiales, según el caso, y por adquirente al peticionario de la inscripción inicial[iii]. En palabras de Viggiola y Molina Quiroga (2015, p. 105): “la inscripción inicial equivale al acta de nacimiento del automotor”.

A su vez, el R.J.A. dispone que la inscripción inicial tiene carácter obligatorio[iv], ya que un vehículo (entendido como medio de transporte) recién se transforma en automotor una vez despachada favorablemente su correspondiente registración inaugural. En otras palabras, a pesar de que un vehículo cuente con los medios físicos y tecnológicos para desplazar cosas o personas, recién podrá ser considerado automotor cuando haya concretado su registración. Esto conviene subrayarlo, ya que antes de la inscripción inicial en el Registro, el vehículo se encuentra sometido a las reglas generales que rigen la adquisición de las cosas muebles. En cambio, la apuntada registración convierte al vehículo en automotor y lo somete a un régimen especial y diferenciado, dando nacimiento a una nueva categoría de cosas muebles registrales.

II- Segunda Parte: Calificación registral y principio de legalidad

En su labor cotidiana, el registrador debe examinar que los instrumentos que se le presentan reúnan los requisitos exigidos por el ordenamiento jurídico a fin de que puedan ser inscriptos o despachados favorablemente, a través de una actividad especial denominada “función calificadora”. Como afirma Díez Picasso (1978), la calificación es el enjuiciamiento que el registrador realiza sobre la legalidad de los documentos y sobre las calidades y la eficacia de los negocios jurídicos contenidos en ellos.

En este aspecto, es importante remarcar que el encargado de un Registro de la Propiedad del Automotor no califica el título (en el sentido de causa-fuente del acto jurídico que sirve de antecedente a la inscripción), sino que es él quien lo expide. Esto deriva del carácter abstracto5 del Registro Nacional de la Propiedad del Automotor, donde no arriban instrumentos que soportan documentalmente el o los negocios jurídicos que sirven de antecedente a la transmisión del derecho real, sino que ingresan rogaciones o peticiones instrumentadas en diversas solicitudes tipos que sólo exteriorizan el consentimiento de las partes.

Para exponerlo claramente, en virtud de esta naturaleza abstracta, una persona no adquiere el derecho real de dominio sobre un automotor desde la formalización de una compraventa, permuta o donación del vehículo, sino desde la inscripción a su nombre en el Registro.

Desde luego, el Registro de la Propiedad del Automotor tiene como uno de sus principios6 fundamentales, el de legalidad, que se traduce en ajustar su obrar conforme al conjunto de normas vigentes. El registrador ocupa un rol central a la hora de examinar la capacidad y legitimidad de las partes, la naturaleza del acto, la correcta identificación del vehículo en cuestión a través de subsumir el trámite o rogación en el cúmulo de leyes que rigen su materia7.

Llegado hasta este horizonte de ideas, considero que, ante la ausencia de una regulación específica en el R.J.A., la cesión de la posición contractual derivada de una factura de compraventa de un vehículo 0 km debe ser encuadrada en el marco de las previsiones contenidas entre los arts. 1.636 y 1.640 del Código Civil y Comercial de la Nación -en adelante C.C.yC.N.-, aprobado por Ley N° 26.994. La regulación legal de esta figura responde a los reclamos efectuados por la mayoría de los autores de la doctrina nacional, aunque cabe destacar que la nueva normativa contiene diferencias marcadas con la tipificación que proponía el proyecto de Código Civil de 1998, como asimismo se aparta de algunos consensos doctrinarios que se habían elaborado sobre el tema.

El principal efecto jurídico del contrato de cesión de la posición contractual es que el cesionario ocupe el lugar del cedente en el contrato base. Algún sector calificado de la doctrina (Carrer, 2000) opina que no se cede el negocio jurídico, sino que se trata de una operación mucho más compleja, donde lo que se transmite son los derechos y obligaciones que nacen del acuerdo, y que pertenecen a las partes en su calidad de tal.

Por eso, estos autores prefieren hablar de cesión de la posición contractual y no de cesión de contrato. Para decirlo en el lenguaje registral, lo que se cede no es el vehículo, sino la posición de adquirente para peticionar la inscripción inicial ante el Registro Nacional de la Propiedad del Automotor. Esta distinción es de vital importancia, como veremos más adelante, a los efectos de calificar la naturaleza jurídica de este tipo de acuerdos y las formalidades exigidas para celebrarlo.

 1) Definición legal de la cesión de la posición contractual

El C.C.yC.N., en su art. 1.636, define este tipo de acuerdos en los siguientes términos:

“En los contratos con prestaciones pendientes cualquiera de las partes puede transmitir a un tercero su posición contractual, si las demás partes lo consienten antes, simultáneamente o después de la cesión”.

“Si la conformidad es previa a la cesión, ésta sólo tiene efectos una vez notificada a las otras partes, en la forma establecida para la notificación al deudor cedido”.

En función de lo regulado en la norma mencionada, la cesión de la posición contractual resulta procedente cuando se encuentran reunidos los siguientes requisitos: a) que exista un contrato con prestaciones pendientes; b) que al menos una de las partes quiera transmitir su calidad de tal a un tercero; y c) que las restantes partes consientan esa transmisión, antes, simultáneamente o después de celebrado el acto que da cuenta de ella.

 2) Partes del contrato. El rol del cedido

La cesión de la posición contractual se configura como un negocio jurídico bilateral, en cuya celebración intervienen dos partes

a-) Cedente: Es aquel que transmite su posición en la relación contractual objeto de la cesión. En nuestra praxis, será

el adquirente mencionado en la factura de compraventa de un vehículo 0 km.

b-) Cesionario: Es aquel que ingresa en el contrato base objeto de la cesión. O sea, sería el peticionario de la inscripción inicial que pretende inscribir el vehículo 0 km en el Registro Nacional de la Propiedad del Automotor.

Ahora bien, en esta figura contractual también interviene el “cedido”, que es aquella parte que permanece invariable en el contrato base. En nuestro tema, estamos hablando de la empresa terminal, fabricante o concesionario que comercializó un vehículo 0 km. Cabe interrogarnos ¿cuál es el rol del cedido?, ¿es necesaria su intervención? Ante el dilema planteado por la fórmula del texto legal, la doctrina abre su cauce a diversas interpretaciones. Para algunos, la conformidad del cedido es elemento constitutivo del contrato de cesión, ya que sin ella el cedente no queda liberado.

En cambio, la tesis contraria sostiene que la conformidad del cedido es un requisito de eficacia para dotarlo de oponibilidad ante terceros. Ahora bien, el art. 1.636 del C.C.yC.N. regula que dicha conformidad puede ser realizada en distintos momentos temporales, lo cual trae aparejada distintas consecuencias jurídicas.

Si la conformidad del cedido se realizó en forma previa o anticipada, al momento de celebrar el contrato-base, es necesario notificar al cedido para que la cesión produzca sus efectos traslativos. Y la forma prescripta para esta notificación es el instrumento público o privado de fecha cierta (Conf. art. 1.620 del C.C.yC.N.).

Si la conformidad del cedido se presta simultáneamente a la cesión, es decir, concurren la manifestación de voluntad del cedente, cesionario y cedido, la cesión produce plenos efectos jurídicos desde su celebración.

Por último, si la conformidad del cedido se realiza con posterioridad a la cesión de posición contractual, ésta recién resulta eficaz y oponible a partir de dicha manifestación de voluntad.

Es importante remarcar que en el supuesto que el cedente no manifieste su conformidad, el contrato de cesión no resulta oponible ni al cedente ni al resto de los terceros, ante quienes seguirá obligado el cedente. Para nuestro caso de laboratorio bajo examen, el registrador debe corroborar la existencia de la conformidad del cedido para que la cesión de la posición contractual sea plenamente eficaz, ya que la inscripción inicial del automotor a nombre del cesionario no sólo tiene efectos constitutivos sino también publicitarios.

 3) Objeto

El principio general en nuestro ordenamiento jurídico es la posibilidad de ceder la posición contractual en cualquier tipo de acuerdos con prestaciones pendientes de ejecución, salvo que sea “intuitu personae”[v], o que existe una prohibición convencional o legal de ceder (Conf. arts. 398 y 1.616 del C.C.yC.N.). Expresado en términos registrales, para ceder la posición contractual de una factura de compraventa de un vehículo 0 km, es preciso que el comprador no haya cumplido su prestación de inscribirlo a su nombre en el Registro de la Propiedad del Automotor. Esta se explica en el hecho que el objeto del contrato de cesión no es el vehículo, sino el plexo de derechos, obligaciones y facultades inherentes a su calidad de adquirente en el contrato de compraventa.

 4) Forma

En este punto, en la doctrina podemos encontrar distintas corrientes interpretativas:

  1. Para un grupo de autores, por aplicación del principio “accesorium sequitur principale”, consideran que el contrato de cesión de la posición contractual debe instrumentarse de acuerdo con la forma prescripta para el contrato-base.
  2. Otra posición sostiene que las normas del C.C.yC.N. no exigen ninguna forma para este tipo de acuerdos, por lo que rige el principio de libertad de formas.
  3. Una tercera vía sostiene que la cesión de la posición contractual es una especie dentro del género cesión9, por lo que cabe aplicar las reglas contenidas en el art. 1.618 del C.C.yC.N. que impone la forma escrita, salvo aquellos casos en que se admite expresamente la transmisión del título por endoso (v.g. depósitos a plazo) o por entrega manual (títulos al portador). Excepcionalmente, el ordenamiento jurídico exige rigurosamente la celebración de una escritura pública, como la cesión de derechos hereditarios, la cesión de derechos litigiosos, o la cesión de derechos derivados de un acto instrumentado por escritura pública.

En nuestra materia, algunos autores expresan que la cesión de la posición contractual de la factura de compraventa de un vehículo 0 km debe formalizarse a través de una nota pura y simple, firmada por el cedente y el cesionario al dorso de la factura. Mascheroni (2015) sostiene que, comentando la norma del art. 1.618 del C.C.yC.N., “al no enunciar expresamente la cesión de factura de venta de un automotor nuevo, debemos interpretar que no es necesaria la escritura pública para ella, sino su simple endoso o entrega manual”.

En idéntica sintonía, Cornejo (2017, págs. 105-106) afirma que “no es necesario ningún recaudo específico para el endoso de dicha factura, ni aun la certificación de firmas de las partes actuantes. Se arriba a esta conclusión, atento que, tratándose la cesión de un contrato entre vivos, y no un trámite en sí ante el Registro, no hay fundamento para exigir una certificación de firmas. Máxime cuando el propio Código Civil y Comercial de la Nación, que dispone los requisitos del contrato de cesión no prevé la necesidad de certificar las firmas de las partes intervinientes. Por lo tanto, sería suficiente la firma del cedente y cesionario, y la correcta individualización del objeto, para tener por formalizado el contrato”.

En este punto, mi tesis es que el contrato de cesión de la posición contractual emergente de una factura de compraventa de un vehículo 0 km debe instrumentarse por escrito, por aplicación de la regla general prescripta en el art. 1.618 del C.C.yC.N. Y, como todo contrato, se requiere el concurso de voluntades del cedente y cesionario, sin perjuicio de lo explicitado sobre la conformidad del cedido. Por lo tanto, en aras a la simplificación de este tipo de acuerdos y la dinámica que tiene la comercialización de vehículos en nuestro país, lo aconsejable es que la cesión de la posición contractual se instrumente por escrito mediante una nota pura y simple, firmada por el cedente, cesionario y cedido al dorso de la factura de venta, donde especifiquen con claridad el vehículo y los alcances de dicho acuerdo. Esta solución no sólo facilitaría la prueba de este tipo de vínculos, sino que posibilitaría la rápida inscripción inicial del vehículo, incorporándolo a su nuevo estatus jurídico de cosa mueble registrable con todas las implicancias que ello trae aparejado al ingresar al Registro Nacional de la Propiedad del Automotor.

 5) Otras cuestiones anexas

Ahora bien, ¿qué sucede que si pesa sobre el cedente una inhibición general de bienes? ¿Esta inhibición impide la inscripción del automotor a nombre del cesionario-peticionario de la inscripción inicial?

Para responder estas inquietudes, debemos tener en cuenta lo apuntado anteriormente, en el sentido que sólo se considera como primera transferencia, para todos los efectos registrales, la que se inscribe en forma inicial en el Registro y tiene como transmitente al fabricante, empresa terminal, comprador declarado en despacho (para los automotores importados) o sus concesionarios oficiales y el peticionario de la inscripción inicial.

En consecuencia, por aplicación analógica de lo normado en la Circular DN 1/2009 (de fecha 28/09/2009), así como son inoponibles a la inscripción inicial las anotaciones de carácter personal que pesan sobre empresas terminales, fabricantes autorizados, compradores declarados en despacho, o sus concesionarios oficiales, tampoco resultaría oponible la inhibición del cedente. El fundamento de esta interpretación es que la inhibición general de bienes sólo impide ejercer actos de disposición sobre bienes y derechos efectivamente incorporados a un patrimonio, situación que no se encuentra configurada en el cedente de su posición contractual.

Relacionado con el argumento anterior, en el supuesto que el cedente sea casado y se encuentre vigente el régimen de comunidad de bienes, no resulta exigible el asentimiento conyugal en los términos del art. 470 del C.C.yC.N. Esta solución se funda en que el texto legal exige el asentimiento del cónyuge para enajenar o gravar bienes registrables y, como vimos, el vehículo 0 km no inscripto se rige por las normas generales de las cosas muebles.

 

 III- Tercera Parte: Reflexiones finales

Actualmente, la posibilidad de ceder la posición contractual derivada de una factura de compraventa de un vehículo 0 km no se encuentra regulada en el menú de trámites tipificados en el Digesto de Normas Técnico-Registrales, emanado de la Dirección Nacional de los Registros Nacionales de la Propiedad del Automotor y de Créditos Prendarios, en cuanto órgano de aplicación del R.J.A.

No obstante, los usos y costumbres vinculados al tráfico comercial de vehículos fueron admitiendo esta “praxis”, por lo que urge la necesidad de brindar una respuesta normativa adecuada y uniforme en los distintos Registros Seccionales de la Propiedad del Automotor distribuidos en todo el país.

Por aplicación del principio de legalidad, considero que la cesión de los derechos emergentes de una factura debe ser encuadra a la luz de las normas contenidas en el C.C.yC.N, en cuanto tronco o raíz originaria donde se funda el derecho común para todo el territorio argentino. Esta aplicación subsidiaria de las reglas del cuerpo civil y comercial encuentra su punto de apoyo en la propia Constitución Nacional y el proceso de génesis del Estado Nacional argentino.

Concretamente, entre las atribuciones que le corresponden al Estado Nacional se encuentra la facultad de dictar los Códigos enunciados en el anterior art. 67, Inc. 11 (hoy art. 75, Inc. 12) de la Carta Magna. En este tópico, Argentina se aparta del modelo constitucional estadounidense, donde cada estado local regula autónomamente lo ateniente a las relaciones jurídicas que se desarrollan en su territorio.

Por el contrario, en pos de constituir la unidad nacional y alcanzar los objetivos enunciados en su Preámbulo, nuestra Ley Fundamental previó que lo más conveniente sería que las instituciones jurídicas sustantivas o de fondo sean reguladas por el Estado Nacional, sin perjuicio de que dichas normas sean aplicadas por las provincias a través de sus propias administraciones de justicia. Así, el gobierno central se reservó para sí el dictado de cuerpos orgánicos y sistemáticos de leyes, llamados Códigos, en el entendimiento que serían la legislación común o compartida en todo el territorio argentino.

Vale la pena recordar las palabras de Alberdi (2010, p. 52), considerado el padre del constitucionalismo argentino, que sostenía: “la legislación civil y comercial argentina debe ser uniforme como ha sido hasta aquí. No sería racional que tuviésemos tantos códigos de comercio, tantas legislaciones civiles, tantos sistemas de hipotecas, como provincias. La uniformidad de la legislación, en estos ramos, no daña en lo mínimo las atribuciones de soberanía local y favorece altamente el desarrollo de nuestra nacionalidad argentina”.

Retomando sobre nuestro camino, cabe remarcar que la posibilidad de ceder una factura de un vehículo no debe ser encuadra normativamente como una transmisión de la propiedad del automotor, ya que el derecho real de dominio recién nace con la inscripción inicial en el Registro. Por lo tanto, no cabe calificar este tipo de acuerdos como una donación del automotor, ni aplicar la regla del art. 1.552 del C.C.yC.N. que exige la escritura pública como formalidad para este tipo negocios jurídicos.

Específicamente, el registrador debe subsumir la cesión de la posición contractual resultante de una factura de un vehículo 0 km en las normas del C.C.yC.N., las cuales regulan este tipo de acuerdo como una especie del género cesión de derechos. Por ello, al momento de analizar la legalidad de la rogación, el encargado debe controlar que se hayan cumplido la forma escrita y la conformidad del cedido para que este tipo de acuerdos sea plenamente válido y oponible a terceros.

Por una cuestión de simplicidad y economía registral, sería aconsejable instrumentar este tipo de acuerdo, al dorso de la factura de venta, con una mera nota suscripta por cedente, cesionario y cedido, donde se individualice el objeto de la cesión y se deje en claro que el cesionario será el peticionario de la inscripción inicial ante el Registro Nacional de la Propiedad del Automotor.

En definitiva, sería pertinente que en un futuro cercano la Dirección Nacional, en cuanto encargada del Registro Nacional de la Propiedad del Automotor, dicte una normativa específica que genere homogeneidad, tanto en el ámbito externo como en el interno, para que los usuarios del sistema registral conozcan a ciencia cierta cómo debe instrumentarse la cesión de la posición contractual y obtener la rápida inscripción inicial del automotor.

Sólo las leyes y su observancia pueden lograr una respuesta unánime, que armonicen plenamente la seguridad jurídica y la libre circulación económica de bienes, valores fundamentales para la existencia de un estado de derecho social y democrático.

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 Alberdi, Juan B.: Bases, Eamp S.A.; 1ª Edición, Buenos Aires, 2010.

 Borella, Alberto O.: Régimen Jurídico del Automotor; Ed. Rubinzal Culzoni, Santa Fe, 1993.

 Caramelo, Gustavo – Picasso, Sebastián – Herrera, Marisa: Código Civil y Comercial de la Nación Comentado; 1ª Edición, Ciudad Autónoma de Buenos Aires, Infojus, 2015.

Carrer, Mario: Cesión de posición contractual; Academia Nacional de Derecho y Ciencias Sociales de Córdoba. Premio Dalmacio Vélez Sarsfield. Tesis sobresalientes, Argentina, 2000.

 Cornejo, Américo A.: Derecho Registral; 4ª Reimpresión, Astrea, Buenos Aires, 2014.

 Cornejo, Javier: Cuestiones registrales del Régimen Jurídico del Automotor; 1ª Edición, Ciudad Autónoma de Buenos Aires, Fundación Centro de Estudios Registrales, 2017.

 Mascheroni, Eduardo: La Cesión de Factura en el nuevo Código Civil y Comercial; Revista Panorama Registral del 6/4/2015 disponible en http://panoramaregistral. blogspot.com/2015/04/la-cesion-defactura-en-el-nuevo-codigo.html

 Molina Quiroga, Eduardo – Viggiola, Lidia E.: Régimen

Jurídico del Automotor; 3ª Edición, Ciudad Autónoma de Buenos Aires, La Ley, 2015.

 Nicolau, Noemí – Hernández, Carlos: Contratos en el Código Civil y Comercial de la Nación; 1ª Reimpresión, Ciudad Autónoma de Buenos Aires, La Ley, 2017.

 Sabene, Sebastián E.: Derecho Registral: una perspectiva multidisciplinaria; 1ª Edición, Ciudad Autónoma de Buenos Aires, La Ley, 2017.

 Sticcone, Mónica: Régimen Registral del Automotor; 1ª Edición, Rosario, 2014.

 Sagüés, Néstor Pedro: Manual de Derecho Constitucional; 1ª Edición, Buenos Aires, Astrea, 2007.

Viggiola, Lidia E. – Molina Quiroga, Eduardo: Decreto Nacional 335/88; 1ª Edición, Ciudad Autónoma de Buenos Aires, Fundación Centro de Estudios Registrales, 2017.

Notas

[1] –  Para ampliar sobre la historia de los automóviles en Argentina, puede verse BREBBIA, ROBERTO H.: Problemática jurídica de los automotores, Ed. Astrea, Bs.As. 1982, Tomo I, p. 3 y ss.; MOISSET DE ESPANÉS, LUIS: Dominio de Automotores y Publicidad Registral, Ed. Hammurabi, Bs. As. 1981, p. 17, o BORELLA, ALBERTO O.: Régimen Registral del Automotor, Ed. Rubinzal Culzoni, Santa Fe, 1993, pp. 15 – 16.

2 –  Al respecto, Viggiola y Molina Quiroga (2015, p. 38) agregan que “La inscripción del automotor en el automotor en el Registro tiene carácter constitutivo, lo que equivale a expresar que mientras no se efectúa, no se produce la adquisición del dominio, sin que tenga trascendencia que el comprador haya o no recibido efectivamente la posesión del automóvil”.

3-  Este razonamiento encuentra regulación positiva en el en el Digesto de Normas Técnico-Registrales en el Título I, Cap. I, Sección 1ª, Parte 3ª, Art. 6° (para automotores nacionales) y en el Título I, Cap. I, Sección 3ª, Art. 9° (para automotores importados).

4-  El carácter obligatorio surge de lo normado en el primer párrafo del art. 6° del R.J.A que establece: “Será obligatoria la inscripción del dominio en el Registro Nacional de la Propiedad del Automotor, de todos los automotores comprendidos en el artículo anterior, de acuerdo con las normas que al efecto se dicten”.

5-  Conviene dejar plasmado que las opiniones doctrinarias no son unánimes en torno al carácter abstracto del Régimen Jurídico del Automotor, ya que existen autores que sostienen que en determinados casos es imposible desentenderse del negocio jurídico base, que es la causa o título de la adquisición del derecho real de dominio. Esto sucede, por ejemplo, en las transferencias ordenadas en el marco de un juicio sucesorio. Sin embargo, el desarrollo de este tema escapa los propósitos del presente trabajo.  6-  Tomando la definición de Cornejo (2017, p. 89) podemos conceptualizar los principios registrales como aquellas “directivas u orientaciones generales en las que se inspira el ordenamiento jurídico, y que desde un punto de vista práctico tienen las siguientes funciones: a) sirven de base previa al legislador para estructurar sus instituciones; b) constituyen instrumentos interpretativos para los diversos actores del sistema; c) facilitan el estudio comparativo de los diferentes ordenamientos registrales”.

6 –  Son aquellos contratos celebrados teniendo en cuenta determinadas condiciones personales de las partes, consideradas esenciales y determinantes, ya que no pueden ser suplidas por otra persona.

7-  Al respecto, el art. 12 del Decreto 335/88, reglamentario del R.J.A., prevé que, “presentada una petición al Registro, el Encargado procederá a su registración o despacho favorable según cual fuere el contenido de la solicitud y siempre que se cumplan los recaudos exigidos por las normas vigentes en la materia”. Y el art. 13 del mismo precepto establece que “en oportunidad de resolver o despachar una petición los Encargados de Registro deberán analizar la situación jurídica registral del automotor y de su titular, la naturaleza del acto cuya inscripción o anotación se peticiona, las peticiones que gocen de prioridad y los actos presentados con posterioridad al trámite que se encuentra a resolución o despacho, cuando se trate de actos que de acuerdo a las disposiciones legales vigentes producen efectos registrales mediante su sola presentación, todo ello, de acuerdo a las normas que rigen la materia y a las disposiciones o instrucciones que imparta la Dirección Nacional”.

9-  Metodológica y estructuralmente, el Código Civil y Comercial de la Nación incluye algunas disposiciones relativas a la cesión de derechos en general y, posteriormente, regula algunos subtipos que ameritan normas específicas de acuerdo con las particularidades del negocio o los derechos cedidos, tales como la transmisión de créditos, de deudas, de posición contractual, de créditos en garantía, de créditos prendarios y la cesión de derechos hereditarios.


.

[iii] –  Este razonamiento encuentra regulación positiva en el en el Digesto de Normas Técnico-Registrales en el Título I, Cap. I, Sección 1ª, Parte 3ª, Art. 6° (para automotores nacionales) y en el Título I, Cap. I, Sección 3ª, Art. 9° (para automotores importados).

[iv] –  El carácter obligatorio surge de lo normado en el primer párrafo del art. 6° del R.J.A que establece: “Será obligatoria la inscripción del dominio en el Registro Nacional de la Propiedad del Automotor, de todos los automotores comprendidos en el artículo anterior, de acuerdo con las normas que al efecto se dicten”.

[v] –  Son aquellos contratos celebrados teniendo en cuenta determinadas condiciones personales de las partes, consideradas esenciales y determinantes, ya que no pueden ser suplidas por otra persona.

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