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A Ação de Despejo no Juizado Especial Cível

DEMÓCRITO RAMOS REINALDO FILHO – Ministro do STJ

1. Ação de despejo para uso próprio
Por ação de despejo deve-se entender o pedido de tutela jurisdicional para se reaver imóvel dado em locação. A lei prevê as hipóteses em que pode ocorrer a extinção da locação, como vencimento do prazo contratual, alienação do imóvel, infração da lei ou do contrato; qualquer motivo, enfim. Em todos os casos, seja qual for o fundamento do término da locação, a ação do locador para recuperar o prédio locado é sempre a de despejo(1). O legislador, no art. 3º, III, da Lei 9.099/95, só considerou como “causa cível de menor complexidade”, no entanto, a ação de despejo que tem um fundamento específico – a retomada para uso próprio(2). Poderia ter estendido o procedimento sumaríssimo, assim entendido como aquele aplicável às causas compreendidas na competência dos Juizados Especiais, a todos os tipos de ações de despejo, quaisquer que fossem os motivos do término da locação, como já houvera previsto o art. 80 da Lei 8.245/91(3). Não o fez, entretanto, tendo em vista aspectos procedimentais peculiares das variadas ações de despejo, determinados pela diversidade dos seus fundamentos. Não só por razões inerentes à própria natureza do direito material, mas também por razões de conveniência de ordem política, social e econômica, de conferir àquele que necessita do imóvel, para o seu uso pessoal, um procedimento mais célere para a retomada.

A expressão uso próprio engloba os fins residenciais bem como qualquer outra destinação que aproveite diretamente o locador. Em outras palavras, este pode pretender a retomada do prédio para nele residir ou usá-lo como sede de empreendimento comercial(4), por exemplo, desde que o proveito auferido do uso da coisa seja sempre pessoal.

2. Despejo por outro fundamento
Tendo o legislador efetuado sua escolha, sobre qual das modalidades de ação de despejo aquela que pode ser considerada de menor complexidade, temos que o legislador estadual não poderá estender a competência dos Juizados Cíveis para alcançar ações que contenham fundamento diverso do uso próprio. Posição em contrário, no entanto, já vem sendo defendida por alguns juristas de nomeada(5). A tese é no sentido de que, com fundamento no art. 93 da Lei 9.099/95(6), que repassa à lei estadual a tarefa de desenhar a organização, composição e competência dos Juizados Especiais, é possível que ações de despejo por outro fundamento possam ser consideradas de menor complexidade, já que a autorização para tanto preexiste no art. 80 da Lei 8.245/91.

A nossa divergência com esse ponto de vista pode ser demonstrada.

A Lei 8.245 (Lei do Inquilinato) foi editada em 18.10.91, ou seja, anos antes do advento da Lei 9.099/95. Quando aquela entrou em vigor, portanto, os Juizados Especiais Cíveis não tinham sequer sido criados. Se os Juizados sequer existiam, como então se explica a previsão constante do seu art. 80? Embora a lei que criou os Juizados ainda não tivesse sido elaborada, a Constituição, àquela época, já continha regra programática de observância obrigatória pelos entes federativos, impondo a estes a criação dos órgãos especiais (art. 98, I). Era previsível, por conseguinte, que a criação dos Juizados, posta no texto legal como um dever governamental dos Estados e da União, seriam criados e instalados num futuro próximo. Foi assim, diante dessa circunstância, que o redator do art. 80 expressou que as ações de despejo poderão ser consideradas como causas cíveis de menor complexidade”. Note-se que não disse, desde logo, que as ações de despejo são consideradas causas de menor complexidade, deixando entrever que apenas continha autorização prévia para a decisão política que somente seria tomada a posteriori, com a edição de Lei 9.099/95, esta sim demarcadora do conceito de “causa cível de menor complexidade. E, como os formuladores da Lei 9.099/95 só fizeram referência à ação de despejo para uso próprio, é porque pretenderam afastar todos os demais tipos de ação de despejo do rol de competência do Juizado Especial.

O art. 80 da Lei 8.245/91, diante das razões expostas, não pode ser considerado como norma definidora de competência. Mesmo que se considere em contrário, ainda assim não pode restar ampliada a competência dos Juizados Especiais para abarcar indistintamente as ações de despejo, pois afigura-se imperioso reconhecer como revogado aquele artigo de lei (o art. 80 da Lei 8.245/91), por aplicação da regra do art. 2º, § 1º, da Lei de Introdução ao Código Civil, que consagra princípio de hermenêutica de elevada importância – o de que a lei posterior revoga a anterior. Com efeito, se no seu art. 3º, a Lei 9.099/95 permitiu a opção pelo Juizado Especial apenas para a ação de despejo para uso próprio, firmou a regra de que em todos os outros casos de despejo não se admite tal opção (“Positio unius, exclusio alterius”). Tendo regulado a matéria de maneira inteiramente diversa, tornando-se incompatível com a Lei 8.245/91 (art. 80), que dá esta como derrogada.

O art. 93 da Lei 9.099/95, é de se ver por fim, não autoriza o legislador estadual a estender a competência do Juizado para o processo e julgamento de causas além daquelas por ela já incluídas. O legislador estadual, em matéria de competência, tem que obedecer aos lindes já demarcados na Lei 9.099/95(7). Como as demais ações de despejo foram por ela afastadas do rol de competência do órgão especialíssimo, as leis locais de organização judiciária não podem desrespeitar seus marcos competencionais(8).

3. Cumulação de pedidos na ação de despejo
Não sendo possível a formulação de pedido de despejo com outro fundamento que não o uso próprio, segue-se que não pode haver pedido com duplo fundamento, verificado na existência da pretensão de retomada com base na utilidade pessoal e qualquer outro dos motivos elencados em lei (Lei 8.245/91) como causa do despejo. Poderá haver, no entanto, e em um caso específico, a cumulação de pedidos. De fato, poderá o locador que pretende retomar o imóvel para dele fazer uso pessoal, cumular o pedido de retomada com o de condenação no pagamento de alugueres, caso estes estejam em atraso, com fundamento no art. 15 da Lei 9.099/95. O pedido de despejo, nesse caso, não terá dupla motivação, pois o seu fundamento permanece único – o uso próprio; apenas se aproveita a permissão da lei processual para, em um mesmo processo, se fazer mais de um pedido, em razão da circunstância de que, entre o pedido de despejo para uso pessoal e o de cobrança dos alugueres, fica evidenciada a existência de identidade da causa petendi(9). Em havendo a cumulação de pedidos, o de cobrança dos alugueres em atraso fica submisso ao valor de alçada (de 40 salários mínimos), já que entra na competência do Juizado Especial pelo inc. l do art. 3º daquele texto legal.

4. Aplicação da Lei 8.245/91 na ação de despejo perante o Juizado Especial
A Lei 9.099/95 não contempla o Código de Processo Civil ou outras leis processuais especiais como fonte de aplicação subsidiária, nos casos por ela omitidos. Isso significa que não se pode, no processo e procedimento por ela instituídos, tomar de empréstimo dispositivos do Código de Processo Civil (ou de leis processuais extravagantes) para instituir formas sacramentais não expressamente nela previstas, em antinomia com a feição dos seus princípios informativos, enunciados no art. 2º. Mas, conquanto não se lhe aplique sempre supletivamente o Código de Processo (ou outras leis de cunho processual), é aceitável que, no silêncio desta lei, as proposições basilares e diretoras constantes de outras leis, como os princípios gerais do processo, e quando não conflitantes com qualquer dos seus critérios informativos, possam ser trazidas para o seio do procedimento sumaríssimo.

Nessa ordem de raciocínio, resta saber se a Lei 8.245, de 18 de outubro de 1991 (Lei do Inquilinato), pode ser aplicada e em que casos ao processo e julgamento das ações de despejo, quando movidas perante os Juizados Especiais, com fundamento no uso próprio.

Cumpre de logo observar que a Lei 8.245 a um só tempo regula as locações de imóveis urbanos e disciplina os procedimentos das ações a ela pertinentes, com o que fica claro que acolhe normas de conteúdo processual e também regras de direito material. A dificuldade reside, assim, inicialmente em se definir a natureza da norma e, uma vez feito isso, quais dentre as de cunho processual, aquelas que podem ser aplicadas sem ferir a índole do procedimento sumaríssimo.

Relativamente ao despejo para uso próprio, inserida no campo do Capítulo II, do Título I, que trata “Das Disposições Especiais”, destaca-se a do art. 47, § 1º, “a”, sobre a exigência do retomante demonstrar a necessidade de usar o imóvel, se estiver ocupando, com a mesma finalidade alegada para a retomada, outro de sua propriedade situado na mesma localidade ou se, embora residindo e utilizando imóvel alheio, já tiver retomado o mesmo imóvel anteriormente.

Trata-se de regra de direito processual, embora não introduzida no Título II (Dos Procedimentos). Com efeito, lei processual não é somente a que regula a forma e a dinâmica do processo – o procedimento -, mas compreende tudo o que se relaciona com a jurisdição civil, daí porque regras sobre o exercício do direito de ação(10) se incluem no espectro das normas processuais. E a norma em destaque (alínea “a” do § 1º, do art. 47) diz respeito ao exercício do direito de ação. Revela especificamente uma “condição de procedibilidade” da ação de despejo com fundamento no uso próprio. Estando ligada ao próprio exercício do direito de ação (mesmo não sendo relativa a procedimento), não pode deixar de ser exigida como condicionamento à decretação do despejo, independentemente do procedimento adotado para atuação em juízo. As condições de procedibilidade da ação, se assim se pode dizer, têm a ver com o próprio direito material, a que estariam jungidas.

Nas ações de despejo aforadas junto ao Juizado Especial Cível, por conseguinte, o locador fica dispensado de demonstrar a necessidade da retomada para uso próprio, que é presumida, a não ser nas hipóteses tratadas no art. 47, § 1º, “a”, (da Lei 8.245/91), preceito de exceção que impõe a prova da necessidade pelo retomante que ocupa outro imóvel de sua propriedade ou que, apesar de residir em prédio alheio, já exerceu o direito de retomada anteriormente. Se, todavia, o pedido para uso próprio for feito por quem reside em prédio alheio e exerce pela primeira vez o direito de retomada, compete-lhe tão-somente a comprovação da propriedade ou do compromisso, nas condições enunciadas no § 2º do art. 47. Nesse último caso, é permitido ao locatário demonstrar a insinceridade do pedido do retomante; tratando-se de simples presunção, a sinceridade da retomada fica afastada ante prova em contrário produzida pelo inquilino.

Deverá também o autor comprovar, ao longo do procedimento sumaríssimo, ser proprietário, promissário comprador ou promissário cessionário, em caráter irrevogável, com imissão na posse do imóvel e título registrado junto à matrícula do mesmo, segundo exige o art. 47, § 2º, da Lei 8.245/91. Cuida-se aqui de pressuposto e condição da ação, e a regra processual que a envolve, igualmente como a do § 1º do mesmo artigo, deverá ser observada em função de regular o exercício do direito de ação, sem guardar uma relação direta com a competência do órgão jurisdicional ou com o procedimento escolhido; é dizer: pouco importando seja a demanda ajuizada na Justiça comum ou ante o Juizado Especial.

Por força dessa regra, portanto, somente estão legitimadas para a propositura da ação de despejo com fundamento no uso próprio, aquelas pessoas indicadas no dispositivo em foco – o proprietário, o promissário comprador ou promissário cessionário, estes dois últimos desde que os títulos (promessa de compra e venda, cessão ou promessa de cessão) atribuam-lhes a condição de dominus em caráter irrevogável(11) e que estejam investidos na posse. Em todos os casos, o exercício do direito de ação pressupõe a comprovação da qualidade do autor, através da inscrição do título no registro imobiliário(12).

Essa regra do § 2º do art. 47 tem sido alvo de críticas, nas mais das vezes infundadas. Alguns entendem que, como o escopo da ação de despejo é a discussão da relação ex locato, e não o jus in re, bastaria a prova da locação para possibilitar a retomada. No caso do locador não corresponder à pessoa que detém o domínio sobre o imóvel, ficaria privado de reavê-lo, alegam os que combatem a norma.

Em outras hipóteses, quando a ação de despejo é movida com fundamento diverso, a legitimação atribuída com exclusividade ao proprietário mostra-se realmente absurda, como nos casos em que a retomada é pedida para a realização de obras no prédio locado (art. 9º, IV e art. 47, IV, c/c art. 60). De fato, nessas situações, o despejo é concedido em face de circunstâncias envolvendo o próprio imóvel, que necessite de reparos, daí porque a ação deveria ser exercitada pelo locador, mesmo não sendo este o proprietário, a exemplo da pessoa que administra o imóvel e recebeu poderes do proprietário para locá-lo em seu próprio nome. Mas no caso do despejo para uso próprio (ou para uso do cônjuge ou companheiro, ou ainda para uso residencial de ascendente ou descendente) a restrição tem razão de ser, pois em não se exigindo a prova da propriedade, aquele administrador do caso citado restaria legitimado ao exercício da ação em nome próprio, e não é essa a intenção da lei. O benefício da retomada, com fundamento no uso próprio ou para uso de familiares, só alcança o senhor da coisa, aquele que detém o domínio(13) sobre o imóvel.

Sendo justamente essa a intenção da lei – a de restringir o pedido de retomada, quando fundamentado no uso próprio, àqueles que detêm o domínio do imóvel -, e como a propriedade de imóvel adquire-se pela transcrição no Registro de Imóveis dos títulos translatícios por ato entre vivos (art. 530, I, do CC), decorre que proprietário somente pode ser considerado aquele que tem título registrado, ficando à mostra a razão pela qual se exige, como condição de exercício da ação, a prova da propriedade por meio de certidão do Registro de Imóveis.

Em determinadas situações ocorrentes na vida prática, no entanto, vamos encontrar pessoas que efetivamente detêm o domínio sobre um bem imóvel, pois que reúnem os requisitos característicos da propriedade (uso, gozo e disposição da coisa), embora sem título registrado. É a situação por exemplo da aquisição de imóveis por pessoas carentes, através de ocupações que acabam sendo regularizadas pelo Poder Público, ou da compra e venda de imóveis de reduzido valor, em que as partes nem sequer celebram o negócio por meio de um contrato escrito. Em todos esses casos, a falta de escrituração e registro do imóvel decorre da ausência de condições mínimas materiais e de informação do proprietário(14). Em geral são pessoas carentes, que não podem arcar com as despesas de registro e escritura, e que têm na renda auferida com o aluguel do imóvel às vezes a única fonte de subsistência.

O jurista não pode ser insensível a essa realidade e, desde que presentes essas condições, não seria desarrazoada uma jurisprudência construída na dispensabilidade do título registrado, para o exercício da ação de despejo. Em se tratando de demanda aforada perante os Juizados Especiais, ainda mais se justificaria a inclinação jurisprudencial por esse caminho, em razão de dois fatores centrais: a existência de uma preocupação social e política na prestação jurisdicional às pessoas mais humildes e suas causas modestas(15), e a presença da regra do art. 6º da Lei 9.099/95, que adere o Juiz de uma maneira ainda mais profunda ao compromisso com a justeza dos julgamentos, ao recomendar que adote “em cada caso a decisão que reputar mais justa e equânime, atendendo aos fins sociais da lei e às exigências do bem comum”.

Já no que diz respeito ao art. 61 da Lei 8.245/91, temos ser de difícil aplicação no processo do Juizado Especial, por envolver norma de natureza eminentemente procedimental, cujos contornos se desviam do procedimento sumaríssimo. Explica-se: o reconhecimento da procedência do pedido, pelo enunciado do citado dispositivo, somente acarreta a concessão do prazo de seis meses, para a desocupação, quando o locatário se dispõe a fazê-lo no prazo da contestação. No procedimento ordinário da ação de despejo tal regra tem sentido porque a contestação é o primeiro ato processual a cargo do réu, cujo prazo para sua realização começa a correr a partir da citação (juntada aos autos do processo do mandado de citação devidamente cumprido – art.). Se, logo que tem ciência da súplica do autor, ao receber a citação, o réu ao invés de contestar o pedido de desocupação, adere à pretensão daquele, beneficia-se com a fixação de prazo bastante largo para efetivar a entrega do imóvel. No procedimento sumaríssimo, por sua vez, o réu não é citado para contestar o pedido, mas para comparecer à audiência preliminar de conciliação, só havendo contestação a posteriori (na oportunidade da audiência de instrução e julgamento), se ultrapassada essa fase inicial. Daí decorre a incompatibilidade do procedimento sumaríssimo com a regra estampada no art. 61 da Lei 8.245/91. Na audiência de instrução e julgamento, ocasião em que no procedimento sumaríssimo o réu contesta a reivindicação feita pelo autor, já escorrera a primeira oportunidade para que pudesse concordar com a desocupação. Nesta fase já se encontraria realizada sem sucesso a tentativa (audiência) conciliatória, onde todos os esforços são concentrados na busca de uma solução conciliada. Não se poderia pensar, pois, em conferir ao réu, dentro do procedimento sumaríssimo, o direito ao prazo elastecido para desocupação, se a concordância com o pedido se perfizer somente na audiência de instrução e julgamento.

Seria mais lógico, então, raciocinar no sentido da possibilidade de atribuição ao réu-locatário do prazo do art. 61 quando a concordância com o pedido ocorre logo na audiência de conciliação, primeira oportunidade que tem de se manifestar no processo, não produzindo, a adoção dessa regra, qualquer deformação no procedimento sumaríssimo, podem imaginar alguns. Pensamos que, mesmo assim, a regra do citado artigo de lei não se conforma com o procedimento sumaríssimo. Volte-se a repetir que a norma em apreço é própria do procedimento especial da ação de despejo, que não se coaduna com o rito sumaríssimo, até porque traz a previsão de dispensa do pagamento de custas e honorários advocatícios fixados na sentença monocrática, como incentivo para que o réu desocupe o prédio no prazo de seis meses, o que seria de total ineficácia em se tratando de ação de despejo ajuizada junto ao Juizado Cível, onde o acesso ao primeiro grau de jurisdição é sempre gratuito, não podendo constar de dispositivo da sentença condenação ao pagamento dos consectários da sucumbência (art. 55, primeira parte, da Lei 9.099/95).

No procedimento sumaríssimo, em caso de concordância com o pedido de despejo logo por ocasião da audiência prévia de conciliação, o prazo de seis meses para desocupação do imóvel poderá ser conferido ao réu não em reconhecimento a um direito subjetivo processual, mas, se for o caso, em cumprimento a acordo celebrado nos autos e homologado por sentença do Juiz. Nada impede, e será em todos os casos proveitoso, que o conciliador sempre faça às partes a proposta de desocupação com prazo mais largo, buscando assim salvaguardar a perceptível intenção do legislador no art. 61 da Lei 8.245/91, que é a de resolver a lide logo no início, impedindo que se desenvolva e consuma o esforço do aparelho judiciário.

5. Valor da causa na ação de despejo
O valor da causa em ação de despejo aforada junto ao Juizado Especial corresponderá, sempre, a doze meses de aluguel, a teor do que prescreve o art. 58, III, da Lei 8.245/91.

À primeira vista pode não parecer importante a fixação do valor da causa na ação de despejo, já que este não influi na competência do órgão especial e que a sentença que julga procedente a ação não inclui condenação em dinheiro, bem como não carrega sobre a parte vencida o ônus da sucumbência, no que diz respeito a honorários advocatícios e custas (art. 55, primeira parte). o valor da causa, entretanto, tem fundamental importância na hipótese de haver recurso da sentença monocrática, pois o ingresso no segundo grau de jurisdição depende da satisfação de custas processuais (preparo prévio, que inclui todas as despesas dispensadas no primeiro grau art. 54, parágrafo único) e pressupõe o pagamento, pelo recorrente vencido, de honorários advocatícios. A gratuidade do acesso ao Juizado se restringe ao primeiro grau de jurisdição. Em caso de recurso, a parte que movimentar a máquina judiciária para promover o reexame da causa, responde por custas processuais e honorários advocatícios, em sofrendo uma derrota no seu julgamento. E a fixação dos honorários, nessa hipótese, que podem variar entre o percentual de dez a quinze por cento, tomará sempre por base de cálculo o valor atribuído à causa, devidamente corrigido (art. 55, parte final), pela simples razão de que nas ações de despejo não há condenação.

6. Execução da sentença de despejo no Juizado Especial
Adota-se, quanto à execução, o processo especial previsto na Lei 8.245/91:
a) a fixação pelo juiz na sentença do prazo de desocupação (art. 63);
b) a execução provisória e a caução correspondente (art. 64);
c) a execução do despejo (art. 65); e
d) a imissão de posse no caso de abandono do prédio (art. 66).

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