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Procedimento Monitório

ERNANE FIDÉLIS DOS SANTOS – Ex-Magistrado de Minas Gerais

1. Certeza, liquidez e exigibilidade em títulos executivos e não executivos
São requisitos dos títulos executivos a certeza, a liquidez e a exigibilidade. A dívida em si, todavia, pode ser certa, líquida e exigível e não se formalizar em título executivo.

O título executivo é de interpretação restrita, definido pela lei, como é o caso da sentença condenatória (art. 584, I e II), da nota promissória e do documento público, assinado pelo devedor, ou do particular, assinado pelo devedor e duas testemunhas (art. 585, I e II). Não se consideram, no entanto, título executivo, por deficiência de forma, o documento particular assinado apenas pelo devedor e a duplicata não aceita, sem prova do recebimento da mercadoria, muito embora estejam definindo, em quantum certo, obrigação não condicionada e sem razão de dúvida ao convencimento do intérprete.

Para efeitos processuais, certeza, liquidez e exigibilidade não têm sentido de definição final, determinando-se, por elas, apenas, hipoteticamente, a obrigação a se cumprir dentro de precisas limitações.

A certeza não é provisória nem definitiva, sendo sempre subjetiva, mas com revelação que a todos afeta, em razão da “… incontrovertibilidad de los datos del conocimiento en determinado momento y em determinado individuo…”, valendo-se da boa explicação de Ugo Rocco(1). Daí dizer-se que a certeza, a determinação do quantum ou da obrigação (liquidez) e a exigibilidade são conceitos processuais, em razão de sua utilidade prática exatamente nas rotas do processo.

2. Noção de título. Dívidas representadas em título executivo ou não
Em sentido jurídico, título é o fundamento do direito, a causa da obrigação. Por isso, diz-se que a dívida pode ser líquida, certa e exigível, sem, no entanto, materializar-se em forma executiva.

Os títulos executivos, em regra, são sempre escritos, mas as dívidas líquidas, certas e exigíveis podem ser representadas por escrito que não tem força de execução, sem perderem a certeza, a liquidez e a exigibilidade.

As legislações reservam a execução, ou processo executório, para a realização jurisdicional de créditos representados por título executivo, conforme definição legal. Para os outros, ou se segue o procedimento de cobrança que venha a criar o título executivo ou procedimento especial que, de alguma forma, alcance a finalidade satisfativa com mais eficácia.

3. Procedimento monitório ou injuncional. Provas escritas e outras provas. Direito Brasileiro
Para títulos que revelem obrigação líquida, certa e exigível, sem terem a forma executiva, as legislações mais avançadas utilizam-se do chamado procedimento monitório ou de injunção, algumas adotando-a apenas para as dívidas representadas por escrito, outras também para as não escritas, orientando-se em razão da matéria.

O CPC, pela Lei nº 9.079, de 17.07.95, adotou o procedimento monitório, sob o título de ação monitória(2).

As fontes alienígenas são, naturalmente, de grande valia na interpretação do instituto, mas o norte de qualquer posição deverá ser o direito brasileiro, mormente no que se refere ao sistema e terminologia da lei que, diga-se de passagem, é esmerada.

4. Objeto mediato do pedido no procedimento monitório. Requisitos do título. Forma escrita. Escrito que emana do próprio devedor e escrito que a lei faz presumir ser dele emanar ou emitido com sua autorização
O objetivo do autor, na denominada ação monitória, pode ser reclamar pagamento de dívida em dinheiro, entrega de coisa fungível, isto é, de bem móvel que pode ser substituído por outro, ou de bem móvel determinado, nunca imóvel.

No procedimento monitório não há sentença. A conjugação do provimento inicial com a inércia do devedor ou com o efeito da improcedência dos embargos cria uma eficácia executiva equiparável à de sentença condenatória, mas não há nem se pode presumir ou admitir declaração jurisdicional de direito nem solução de litígio. Daí não se servir o processo a indagações que possam declarar direito para efeito de formação de título executivo. As obrigações, embora não vazadas em título de execução, devem, em sentido processual, ser incontroversas e devidamente limitadas, isto é, com os requisitos de convencimento que informam a certeza, a liquidez e a exigibilidade(3). Por exemplo, devo ao Fulano R$ 1.000,00 pagáveis em dia X; entregar-lhe-ei 50 sacas de café tipo Y, em tal dia; dar-lhe-ei como pagamento da dívida que reconheço meu veículo Chevrolet, ano 1994, etc., etc.

A obrigação deve estar representada por escrito, mas sem que o mesmo lhe empreste forma executiva (art. 1.102a), porque, se assim estiver, não há interesse em formação de título já formado. É de se fazerem, contudo, duas importantes observações: Para o monitório, irrelevante será a possibilidade de outro procedimento para a satisfação do auto, ainda que mais eficaz. Em caso de restituição de bem móvel dado em comodato, hábil é o pedido possessório, mas, se a obrigação de restituir estiver vazada em escrito, sem força executiva, possível será a ação monitória. As cambiais, formalizadas, ensejam ação executória, mas, se o autor desinteressar-se da força própria do título, tomando-o apenas com declaração de existência de dívida, poderá provocar a injunção. Evidentemente que o procedimento será útil no caso de a dívida cambial estar prescrita, como declaração ou não, porque, aí, relatando o negócio subjacente e reclamando o pagamento respectivo, a cártula servirá apenas de documento escrito, sem força executiva, mas com liquidez e certeza da dívida que autorizam o pedido monitório.

Não é qualquer forma escrita que faz o título hábil para o pedido monitório. Mister que o que nela se contém revele obrigação certa, líquida e exigível. Declaração de terceiros, por exemplo, não dá certeza da dívida nem o sacado que não aceitou a letra de câmbio pode ser considerado devedor certo na obrigação.

O documento escrito mais comum do título monitório é o que vem assinado pelo próprio devedor, não importa qual seja a forma, a exemplo dos contratos, das declarações unilaterais com informação ou não da causa da obrigação, das missivas ou dos meros bilhetes. A lei e, às vezes, o próprio teor das disposições contratuais fazem presumir que certas formas escritas, embora não contendo assinatura do devedor, revelem certeza e liquidez processuais da obrigação. A duplicata mercantil sem aceite só tem executividade quando há prova do contrato e do recebimento da mercadoria, mas, na pressuposição de que ela nunca se expede sem que haja negócio comercial, sua emissão faz considerar-se a existência da dívida em dado momento, embora falte ao título a executividade. As contas expedidas pelas empresas de água, luz e telefone, os saldos bancários, com prova do contrato do correntista são também, exemplificativamente, formas hábeis de se presumir, em um primeiro momento, a existência da dívida e permitir a instauração do procedimento monitório(4).

Exemplos bastante significativos no direito estrangeiro são os telegramas e similares que, por seu teor e levando-se em conta a natureza da fonte, geram presunção de autenticidade das declarações, autorizando, em conseqüência, a indagação monitória(5).

5. Despacho de deferimento. Forma e natureza
O despacho de deferimento, fundado em petição devidamente instruída, importa, nos termos da lei (art. 1.102b) em mandado de pagamento ou de entrega (atente-se para o termo “de pagamento ou de entrega”, não “para pagamento ou para entrega”), dirigido ao devedor, permitindo-se-lhe que atenda em quinze dias.

O provimento judicial que defere a inicial não tem nenhum efeito declaratório de direito nem de qualquer condenação. Não é sentença nem decisão interlocutória, porque, na verdade, nada decide(6). Certo é que o Juiz, fazendo exame dos fatos, expede o provimento adequado, parecendo relevar decisão jurisdicional, mas este não é o sentido do processo de conhecimento. Em qualquer despacho ordinatório, há sempre teor decisório, mas nunca no sentido de solucionar questões entre as partes e sim de reconhecer-lhes prerrogativas processuais, garantidas pela lei. Do contrário ter-se-ia de admitir, com maior razão, que o deferimento da execução seria também sentença ou interlocutória e não apenas provimento que reconhece o direito ao processo executivo.

A formação do título executório se completa com a improcedência dos embargos (art. 1.102a, § 3º) ou com sua não interposição (art. 1.102 caput), o que equivale dizer que a eficácia análoga à condenatória jamais poderá ter partido de provimento anterior, vedando-se-lhe, em conseqüência, a natureza de sentença ou de decisão interlocutória dos efeitos pretendidos.

O certo é que se forma o título executivo pela participação omissiva do devedor, não apresentando defesa hábil a impedir os efeitos da certeza e liquidez do momento da dívida, ou pela improcedência de sua oposição. O título tem natureza judicial, porque as respectivas conseqüências se deram no processo, e muito mais, em razão do processo, como, de resto, deveria necessariamente ser.

6. Cumprimento da obrigação pelo devedor. Isenção de custas e honorários
A atitude do devedor, ao receber a citação, poderá ser a de atender o mandado, silenciar-se ou apresentar embargos.

Atendendo o mandado, o devedor, até então considerado réu pela lei, poderá pagar, ficando isento de custas e honorários advocatícios (art. 1.102, § 1º). A razão da isenção é a de que, até este momento, não há nem efeito condenatório nem de resistência à pretensão insatisfeita, sendo finalidade procedimental a formação do título executivo.

O atendimento da pretensão deve ser consoante ao pedido, não sendo lícito ao devedor pretender reduzir a importância cobrada ou modificar a pretensão de recebimento de bem móvel. Qualquer questão a respeito só se soluciona com os embargos que a ele se facultam.

7. Inércia do devedor. Formação do título executivo e instauração imediata do processo de execução
Se o devedor não paga nem se defende, considerar-se-á, com a omissão, formado o título executivo, instaurando-se o processo executório, na sua forma comum, inclusive com citação para entrega da coisa ou depósito (art. 621) e citação com a respectiva penhora, se não houver pagamento (art. 652).

8. Embargos do devedor. Natureza dos embargos. Objetivo. Processamento. Rejeição, improcedência e instauração da execução. Embargos parciais e procedência parcial
O devedor, ao receber mandado de entrega ou de pagamento, poderá embargar, no prazo de quinze dias, sem necessidade de segurança do juízo (art. 1.102c), mesmo porque o Estado ainda não se encarregou de qualquer forma executória.

Não importam, em absoluto, as finalidades defensivas. A lei classificou a defesa como embargos, expressão usada no CPC como forma de recurso (embargos infringentes e embargos declaratórios), como forma de defesa proibitiva (nunciação à obra nova), como forma de reintegração ou manutenção de posse de bens apreendidos judicialmente (embargos de terceiro) e como desconstituição da execução que pode atingir também a desconstituição do título executivo, com declaração de inexistência de dívida (embargos do devedor). Como não se trata de recurso nem se relaciona com “obra nova” ou defesa de posse, os embargos só podem ter finalidade defensiva e, neste caso, do devedor, que, é claro, não pode ser considerado terceiro na relação.

Os embargos do devedor são ação de conhecimento incidente. Na execução objetivam ou a desconstituição do título executivo, com a conseqüente declaração de inexistência da dívida, ou o reconhecimento da impropriedade do processo executório. No procedimento monitório, não há ainda título executivo a se desconstituir, mas, em razão da forma em que a dívida se representa, goza de presunção de certeza e liquidez, para os efeitos processuais previstos. Neste caso, os embargos poderão atacar a própria presunção e desconstituir o procedimento monitório ou, então, com o mesmo efeito e, mais ainda, declarar a inexistência da dívida.

Os embargos são processados nos mesmos autos do procedimento (art. 1.102c, § 2º), situação que não lhes altera a natureza, já que se trata de simples opção de comodidade procedimental.

Com a rejeição liminar dos embargos ou com sua improcedência, a execução se inicia, tomando seu curso normal (art. 1.102c, § 3º).

Os embargos podem ser parciais, isto é, versarem apenas sobre parte da dívida reclamada, caso em que, considerando-se formado o título quanto ao restante não impugnado, poderá a execução respectiva ser instaurada separadamente.

Os embargos podem ser também julgados procedentes apenas em parte. Em tais hipóteses, a formação do título executivo limitar-se-á ao que restar.

9. Recursos e efeitos
Sendo simples despacho ordinatório, não há recurso contra o provimento que defere o procedimento monitório. Ainda que irregularmente concedido, apenas os embargos do devedor são capazes de desconstituí-lo, ocorrendo preclusão, caso não sejam interpostos.

Os embargos do devedor, no procedimento monitório, ainda não são à execução. Neste caso, o recurso que os julga é apelação, recebido em ambos os efeitos, porque a exceção, de interpretação restrita, só se reserva aos embargos à execução (art. 520, V).

O não recebimento dos embargos, isto é, sua rejeição liminar, não gera nenhum efeito; logo, não há suspensividade a se resguardar, devendo o processo caminhar normalmente em tal hipótese.

10. Natureza judicial do título formado no procedimento monitório. Embargos à execução e limitação respectiva. Possibilidade de ações referentes à dívida e limitação da coisa julgada
O devedor tem a faculdade de apresentar ampla defesa, através de embargos, na fase preparatória da formação do título executivo, mas não lhe ficaram vedados os embargos à execução subseqüente, após a segurança do juízo (art. 1.102c e § 3º). Pergunta-se então: Por ser título executivo judicial, os segundos embargos ficarão limitados às hipóteses do art. 741 do CPC ou poderão ser amplos (art. 745), certamente resguardados os limites da coisa julgada?
O Juiz, quando homologa laudo arbitral, conciliação ou transação, o faz através de sentença de pura deliberação, isto é, de observância da validade formal do ato. Neste caso, ilógico seria restringirem-se os embargos às defesas próprias contra o título judicial, quando, na verdade, nem o Juiz nem o processo tiveram influência na formação do título executivo, quanto a sua substância. Entretanto, com o título que advém do procedimento monitório, a situação é bem outra. Não há propriamente participação conjunta das partes no acertamento da relação jurídica, mas mera provocação de uma delas, com a formação do título operando-se não por vontades conjugadas, mas por conseqüência específica do processo, como fruto de seu próprio desenvolvimento. Por isso, é lógico que o título, considerado assim judicialmente constituído, tenha força total de título judicial, com os embargos interpostos contra a execução propriamente dita admitidos apenas nas hipóteses restritas do art. 741.

A consideração da natureza judicial do título formado no procedimento monitório não tem força de suplantar os preceitos informativos da coisa julgada. A simples observância dos requisitos da dívida representada por título não executivo, bem como sua constituição por inércia do devedor, não importam em declaração de direito e obrigação(7). Em conseqüência, dos resultados concretos do procedimento monitório não há coisa julgada, podendo a matéria ser apresentada e discutida, e as questões respectivas decididas, em processo de conhecimento, com as conseqüências que lhe forem próprias(8).

Na hipótese de a formação do título ter-se dado por improcedência dos embargos, poderá ocorrer coisa julgada, mas nos limites em que foram interpostos (art. 468 do CPC).

11. Restrição do procedimento monitório a pessoas jurídicas de direito público e incapazes
Ao se omitir na apresentação de embargos, o devedor provoca a criação de título, o que equivale dizer que tal ato tem efeitos análogos ao reconhecimento de pedido no processo de conhecimento. Em conseqüência, pessoas jurídicas de direito público, cujos representantes não tenham poder de transacionar, não podem figurar no pólo passivo da relação processual no procedimento monitório, devendo dizer o mesmo com relação aos incapazes não autorizados.

12. Formas de citação. Impossibilidade de citação ficta
Qualquer forma de citação direta é possível no procedimento monitório, como é o caso das que se fazem por correio e por mandado. A citação ficta, edital e hora certa, não se comporta, porém, no procedimento, porque, de alguma forma, para aceitação da formação de título por omissão de defesa, há mister efetiva manifestação de vontade, que está além dos poderes de atuação do curador. Este, por outro lado, com a simples missão de se opor em defesa, não pode demonstrar interesse a embargos, que são verdadeira ação.

Na impossibilidade, pois, de citação direta, ao credor só resta a opção do processo de conhecimento.

13. Natureza executiva do procedimento monitório.

No sistema processual brasileiro, conhecem-se três espécies de processo: o de conhecimento, o de execução e o cautelar. Os procedimentos especiais, tratados no Livro IV do CPC, são todos de processo de conhecimento. A ação monitória, nele incluída, foi considerada, portanto, procedimento de processo de conhecimento.

Moderna doutrina chama de tutela diferenciada(9) o procedimento que contém a reunião de vários procedimentos em um só. O critério, porém, não se adapta ao sistema do Código.

O fim específico do procedimento monitório é a formação de título executivo e o objetivo do pedido, em primeiro plano, é de recebimento coativo da dívida; logo, de execução. Os atos que seriam próprios de processo de conhecimento não se concluem como tais, porque o procedimento completo não enseja seu término por sentença jurisdicional. Objetivando, pois, a execução, tais atos são mero adendo, de natureza preparatória, do processo respectivo.

Sendo a defesa do devedor exercitável somente através de embargos, o incidente, como na execução, não é da essência do procedimento, sendo mera concessão do legislador, já que a dívida, muito embora não se represente por título executivo, goza de presunção de certeza e liquidez, para efeitos processuais.

Afora a decisão dos embargos, não há, no procedimento monitório, sentença de cognição, donde se concluir Chiovenda, ser ele “Dotado, …, de função preeminentemente executiva(10)”. Lógica seria, pois, sua inclusão no Livro II (Processo de Execução).

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