CeCapSandes

Princípio da Reserva de Plenário

Olá, meu amigo e minha amiga,

Hoje eu trago para seu conhecimento noções sobre o princípio da reserva de plenário.

Com efeito, o nosso sistema de controle de constitucionalidade, que é forte, admite que os órgãos jurisdicionais de 1ª instância (juiz da vara do trabalho, da vara cível ou federal etc) podem decidir sobre a inconstitucionalidade de leis ou atos normativos submetidos ao controle concreto (naquela situação casuística), podendo fazê-lo até mesmo de ofício. Assim, podemos afirmar que não é condição de eficácia das decisões de inconstitucionalidade emanadas das Varas do Trabalho, das Varas Cíveis, dos Juízes de Juizados Especiais, além de outros, o princípio da reserva de plenário, pois são órgãos integrantes da primeira instância da organização judiciária e, notadamente, singulares.

Vale dizer que o princípio da reserva de plenário só é aplicado nos tribunais, no exercício do primeiro (competência originária) ou do segundo (competência recursal) grau de jurisdição.

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. Em resumo: o princípio da reserva de plenário, previsto no art. 97 da Constituição determina que somente pela maioria absoluta dos seus membros ou do seu órgão especial, poderão os tribunais declarar a inconstitucionalidade de lei ou ato normativo do Poder Público.

Nos termos do art. 948 do CPC, arguida, em controle difuso, a inconstitucionalidade de lei ou de ato normativo do poder público, o relator, após ouvido o MP e as partes, submeterá a questão à turma ou à câmara à qual competir o conhecimento do processo. E, ademais, se a arguição for rejeitada, prosseguirá o julgamento. No entanto, se acolhida, a questão será submetida ao plenário do tribunal ou ao seu órgão especial onde houver.

O STF, em decisões anteriores a vigência do CPC/15, já admitia, excepcionalmente, ser dispensável a aplicação do art. 97 da CF quando: a) o plenário do STF já tiver se manifestado sobre a inconstitucionalidade da espécie normativa; b) houver manifestação do tribunal a quo em relação aquela mesma lei ou ato normativo.

Assim, podem os órgãos fracionários (Turmas ou Câmaras) declararem a inconstitucionalidade sem observar a reserva de plenário (art. 949, parágrafo único do CPC/15), já tendo o STF se manifestado sobre a constitucionalidade de dispositivo similar, o antigo art. 481, parágrafo único, CPC73 (STF. AgIn nº. 169.964. Rel. Min. Marco Aurélio), devendo ser observada, por outro lado, a Súmula Vinculante n. 10 do Pretório Excelso, que assim preceitua: “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.”

Cordial abraço e bons estudos,

Fagner Sandes – Instagram: @prof.fagner.sandes

 

ADQUIRA O CURSO DE DIREITO CONSTITUCIONAL EM ATÉ 10 VEZES SEM JUROS!

julho 26, 2019

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