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CONTROLE DE CONSTITUCIONALIDADE JUDICIAL PELA VIA INCIDENTAL NO PROCESSO DO TRABALHO

  1. Aspectos Propedêuticos

 

Não é raro, seja ministrando aulas em cursos, faculdades, pós-graduação ou, até mesmo, nos corredores do fórum trabalhista, algum aluno ou colega me indagar sobre a possibilidade ou não de arguição de inconstitucionalidades perante qualquer juiz do trabalho. Minha resposta sempre é: Sim! Claro que é possível.

Com efeito, essa espécie de controle, denominado difuso ou aberto, caracteriza-se pela permissão a todo e qualquer juiz (entenda-se juízo) ou tribunal, perquirir no caso concreto acerca da adequação da norma apontada como inconstitucional com a Constituição.

Observe-se que o STF já decidiu que qualquer juiz de 1ª instância pode declarar, pela via de exceção, a inconstitucionalidade de um ato normativo, como se extrai do RE 117.805/PR, cujo relator fora o eminente Min. Sepúlveda Pertence. Tal posição do Pretório Excelso permanece até os dias atuais e faz parte do nosso sistema de Jurisdição Constitucional.

Vale dizer que no controle difuso, a manifestação do Judiciário sobre a inconstitucionalidade não é o objeto principal da lide, mas sim questão prévia, necessária para o julgamento do mérito, devendo ser arguida como matéria de prejudicial de mérito. Por esta razão, a decisão sobre a inconstitucionalidade não faz coisa julgada erga omnes, pois ventilada na fundamentação da sentença, onde o órgão jurisdicional declara sua inaplicabilidade entre as partes litigantes, não alcançando terceiros estranhos à lide, exceto se julgada pelo STF via recurso extraordinário, caso o Senado Federal, após notificado pelo STF sobre a decisão, suspenda os efeitos da norma no todo em parte, o que, segundo parte da doutrina, terá efeito ex nunc, ou seja, a partir da edição da resolução que suspender a espécie normativa.

No entanto, impera ressaltar que recentemente, o STF no julgamento das ADI´s 3406 e 3470, registrou a declaração de inconstitucionalidade incidental com efeito vinculante e eficácia erga omnes, o que já vinha sendo debatida no STF há alguma tempo, em razão de pensamento do Min Gilmar Mendes.

Por este pensar, há releitura do disposto no art. 52, X da Constituição, vez que a Corte Suprema irá comunicar o Senado não para fins de eficácia da decisão, mas para que ele intensifique a publicidade, ou seja, o artigo 52, X, da CF sofreu, e isso é evidente, uma mutação constitucional, de modo a conferir à resolução do Senado caráter meramente declaratório.

Com efeito, pela via de defesa, a inconstitucionalidade pode ser argüida em qualquer ação, bem como as de nível constitucional como habeas corpus e mandado de segurança, de modo que o controle difuso só pode ser realizado em caso concreto, pois a norma tida como inconstitucional prejudica, previamente, o exercício/gozo de algum direito.

2. Reserva de Plenário (Full Bench ou Full Court)

Vimos que na 1ª instância compete ao juízo decidir sobre a inconstitucionalidade da espécie normativa submetida ao controle concreto, até mesmo de ofício. Logo, não é condição de eficácia das decisões de inconstitucionalidade emanadas das Varas do Trabalho, o princípio da reserva de plenário, pois são órgãos integrantes da primeira instância da organização judiciária trabalhista.

Pois bem, o princípio da reserva de plenário só é aplicado nos tribunais ou em seus respectivos órgãos especiais, onde houver e desde que tenha havido delegação dessa atribuição pelo tribunal pleno, nos termos do art. 97 e art. 93, XI, ambos da CRFB/88.

Assim, para que tenha eficácia à decisão acerca da inconstitucionalidade de lei ou de ato normativo exarada pelos tribunais ou, onde houver, órgão especial, é necessário a declaração pela maioria absoluta de seus membros, sob pena de nulidade da decisão.

O STF, no particular, adotou a Súmula Vinculante n. 10, com o seguinte conteúdo: “Viola a cláusula de reserva de plenário (CF, artigo 97) a decisão de órgão fracionário de Tribunal que embora não declare expressamente a inconstitucionalidade de lei ou ato normativo do poder público, afasta sua incidência, no todo ou em parte”.

Não obstante, se arguida nos Tribunais, é imperioso, sem prejuízo da observância das normas regimentais, a observância do que dispõem o art. 948 ao art. 950 do CPC vigente, no que couber, de modo que podem os órgãos fracionários dos Tribunais (Turmas) declararem a inconstitucionalidade sem observar a reserva de plenário quando já houver pronunciamento destes ou do plenário do Supremo Tribunal Federal sobre a questão.

O STF se manifestou a respeito do tema, mas na vigência do CPC de 1973 (STF. AgIn nº. 169.964. Rel. Min. Marco Aurélio), devendo ser observada, por outro lado, a Súmula Vinculante n. 10 do Pretório Excelso.

 

3. Efeitos da Decisão

 

Declarada de forma incidental a inconstitucionalidade de um ato normativo, ele se desfaz na origem, esvaziando as consequências dele decorrentes, porque destituído de qualquer eficácia jurídica, os efeitos serão ex tunc (retroativos) e inter partes (entre as partes).

Note-se que a Constituição, prevê uma forma de ampliar esses efeitos, se o STF decidir incidentalmente a inconstitucionalidade, pois neste caso, como já dito acima, o Senado Federal poderia editar uma resolução suspendendo a execução no todo ou em parte da lei declarada inconstitucional em decisão definitiva do STF, que terá efeito erga omnes e ex nunc, ou seja, com validade a partir da publicação da resolução.

O Senado Federal não está vinculado a editar a resolução, pois tal atividade é discricionária. Porém, se editar a resolução, terá exaurido sua competência constitucional, não podendo alterar sua decisão posteriormente.

Ressalte-se ainda que, para uma corrente, o Senado Federal poderia suspender parcialmente a lei declarada inconstitucional, com base na teoria dos poderes implícitos (quem pode o mais pode o menos). Mas o STF entende que se o Senado assim o fizer estará violando o princípio democrático e praticando usurpação de função, vez que estaria apreciando novamente a constitucionalidade da norma.

Sendo assim, entendemos que o STF no julgamento das ADI´s 3406 e 3470, como noticiamos ao norte, acertou, vez que como guardião das normas constitucionais, deve ter, necessariamente, a legitimidade de expurgar, de plano, normas inconstitucionais do ordenamento jurídico.

 

  1. Algumas Hipóteses para Arguição

 

A toda evidência, caso alguma das matérias abaixo venha a ser declarada constitucional (ADC) ou inconstitucional (ADI) pelo Supremo Tribunal Federal, não há mais razão para se arguir, em razão da eficácia vinculante e erga omnes que ostenta qualquer decisão do STF em sede de controle direito de inconstitucionalidade exarada por aquele órgão.

Vale dizer que as situações abaixo são apenas exemplificativas. Não temos a pretensão de esgotar o tema. No entanto, importa dizer que, em nosso sentir, além de questões específicas, qualquer norma que venha a trazer prejuízo no que toca a condição social do trabalhador é inconstitucional, tendo em vista o disposto no caput do art. 7º da CF.

Seguem arroladas de forma meramente exemplificativa, em nosso sentir, algumas disposições da CLT que violam o Texto Magno:

 

1) §2º, art. 8º, CLT. Parâmetro: art. 2º da CF e outros.

2) §5º, art. 59, CLT. Parâmetro: art. 7º, XIII CF.

3) §1º, I, II, III e IV. Art. 223-G, CLT. Parâmetro: dignidade da pessoa humana e outros.

4) §2º, art. 468, CLT. Parâmetro: direito adquirido e outros.

5) Parágrafo único do art. 613-B. Parâmetro: saúde e segurança do trabalhador, além de outros incisos do art. 7º da CF;

6) art. 702, I, “f”, §§ 3º e 4º da CF. Parâmetro: art. 2º, art. 96, I, CF e outros.

7) art. 790-B, parágrafo único. Parâmetro: Acesso à justiça e outros.

8) art. 791-A (percentual dos honorários). Parâmetro: igualdade, razoabilidade e outros, já que o CPC estabelece de 10% a 20%;

9) §4º do art. 791-A. Parâmetro: Acesso à justiça e outros.

10) parte do §2º do art. 844 e §3º na íntegra. Parâmetro: Acesso à justiça e outros.

 

Com relação a esse último item acima (existem outras hipóteses), o Tribunal Regional do Trabalho da 3º Região aprovou a Súmula 72, a qual deve ser utilizada por nós, estabelecendo:

 

         São inconstitucionais a expressão “ainda que beneficiário da justiça gratuita”, constante do § 2º, e a íntegra do § 3º, ambos dispositivos do art. 844 da CLT, na redação dada pela Lei 13.467/2017, por violação direta e frontal aos princípios constitucionais da isonomia (art. 5º, caput, da CR), da inafastabilidade da jurisdição (art. 5º, XXXV, da CR) e da concessão de justiça gratuita àqueles que dela necessitarem (art. 5º, LXXIV, da CR). (RA 145/2018, disponibilização: DEJT/TRT3/Cad. Jud. 19, 20 e 21/09/2018).

 

Como disse, não pretendo exaurir o tema, mas apresentar alguns questões essenciais e, acredito, consegui meu objetivo.

 

Caso tenha alguma dúvida, pode entrar em contato pelo e-mail fagnersandes@gmail.com

 

Cordial abraço,

 

          Fagner Sandes – Advogado, Mestre, Professor, Palestrante e Consultor.

abril 16, 2019

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