Tengo un conflicto vecinal en un garaje debido a un propietario que excede en bastante (20 cm) la línea que delimita su plaza con el pasillo, lo que dificulta el aparcamiento de los demás propietarios próximos.

Ya le hemos indicado en persona y por escrito en varias ocasiones, tanto el propietario como yo, haciendo caso omiso, por lo que querría saber que mas se puede hacer y pasos a tomar.

Un saludo.Respuesta:

Estimado asociado:

Una de las vías que se podría adoptar en el caso de propietarios de inmuebles, o incluso inquilinos, que estacionen sus vehículos en todo o parte de las zonas de elementos comunes es la de recurrir a la vía del art. 710 Ley de Enjuiciamiento Civil que prevé el ejercicio de acciones judiciales tendentes a conseguir de una persona, en este caso el demandado, que se abstenga de actuar en un sentido. Es esta una acción civil dirigida a obtener de una persona un no actuar o no comportarse de una manera concreta obteniendo, en su caso, del órgano judicial una resolución judicial en forma de sentencia que le compele al demandado a abstenerse en lo sucesivo de actuar en la forma que constaba en la demanda y que ha sido fijado en la sentencia.

Bajo esta figura procesal de las demandas dirigidas a obtener un “no hacer” de una persona o abstenerse de llevar a cabo determinada conducta recordaremos que el propio art. 710 LEC señala que: Si el condenado a no hacer alguna cosa quebrantare la sentencia, se le requerirá, a instancia del ejecutante por parte del Secretario judicial responsable de la ejecución, para que deshaga lo mal hecho si fuere posible, indemnice los daños y perjuicios causados y, en su caso, se abstenga de reiterar el quebrantamiento, con apercibimiento de incurrir en el delito de desobediencia a la autoridad judicial. Se procederá de esta forma cuantas veces incumpla la condena y para que deshaga lo mal hecho se le intimará por el Secretario judicial con la imposición de multas por cada mes que transcurra sin deshacerlo.

Quiere esto decir que es una fórmula dirigida a conseguir de un comunero que en lo sucesivo no vuelva a estacionar su vehículo en plazas que no sean las suyas o en elementos comunes, obteniendo la comunidad de propietarios un título judicial cual es el de una sentencia que le compele al comunero incumplidor de abstenerse de seguir con su actuación. Y es para el caso en el que persista en su conducta cuando se le requerirá judicialmente para que la abandone, con la posibilidad de proceder penalmente contra el comunero por delito de desobediencia y, además, con la posibilidad de imponerle multas el órgano judicial en caso de desobediencia. De lo que se trata con esta fórmula es de evitar que los comuneros entiendan que la comunidad no dispone de herramientas legales para hacerles frente a su conducta insolidaria, amparados quizás por el conocimiento de que no se puede recurrir a la grúa municipal para que se retire el vehículo de una zona no autorizada al tratarse de una cuestión de derecho privado que corresponde solucionar a la propia comunidad de propietarios.

Otra forma para enfocar el problema se centra en utilizar el cauce del art. 7.2 Ley de Propiedad Horizontal para seguir el iter de este precepto que articula un sistema para hacer frente primero en el ámbito de la propia comunidad a las actividades realizadas por los comuneros que causen perjuicios a los demás, para lo que el propio art. 7.2 LPH señala que el propio presidente de la comunidad requerirá al comunero y/o al inquilino para que cese en su actividad molesta, ya que como tal debe considerarse la conducta habitual del comunero o inquilino consistente en estacionar indebidamente su vehículo en la comunidad. Este requerimiento del presidente se podrá ejecutar por el administrador de fincas, y como tal exige su fehaciencia; es decir, que conste su recepción, ya que frente a los actos de comunicación de convocatorias de juntas o notificaciones de actas de la celebración de una junta de propietarios que no exigen la fehaciencia en la comunicación, en estos casos se está tratando de requerimientos, y esta modalidad de acto de comunicación se configura bajo la exigencia de que conste formalmente que se ha recibido por el afectado el contenido de por qué se le requiere. La cuestión consiste en delimitar que esta conducta del comunero se trata de una actividad molesta y que, como tal, la comunidad no debe estar dispuesta a soportar o tolerar, de tal manera que si ha sido requerido para se abstenga del ejercicio de esta actividad y vuelve a hacerlo, la comunidad estará legitimada para, en una junta extraordinaria o en la anual ordinaria, acordar por mayoría simple el ejercicio de acciones judiciales frente al comunero y/o inquilino, a fin de que se estime la acción de cesación ejercitada por la comunidad de propietarios y se le condene a que cese en su conducta.

En cualquier caso, si se obtiene la sentencia firme que le condena a cesar en su conducta, en caso de no aceptación de la sentencia se le podrá requerir para que cese en la misma, pero ya en este caso por el órgano judicial en la misma forma que previene el art. 710 LEC  antes visto, con la advertencia de que de persistir se abrirán unas diligencias penales por delito de desobediencia a la autoridad judicial, por lo que en este caso debería responder penalmente de una conducta a la que el propio comunero no le daba importancia, pero que por la acción judicial de la comunidad le lleva a dar cuenta de la misma ante un juez penal.

En cualquier caso, somos conscientes de que el ejercicio tanto de esta vía como de la del art. 710 LEC conlleva que la comunidad de propietarios tenga que esperar al pronunciamiento de una sentencia firme para poder actuar finalmente, lo que puede llevar su tiempo, cuando el comunero puede seguir incumpliendo la “prohibición” que existe de aparcar en zonas no autorizadas, o en plazas que no sean suyas. Indudablemente, esto puede llevar a serios problemas internos en la comunidad, porque puede pensarse en las situaciones de violencia que pueden desencadenarse en estos casos ante vecinos que dejan estacionados sus vehículos en plazas de otros, o en zonas que perjudican el libre paso de vehículos o en zonas no autorizadas. Generalmente, los conserjes suelen poner carteles o notas explicativas en los parabrisas de estas personas haciéndoles la advertencia de que desistan de sus conductas.

Quizás, una solución que se nos ocurre es que el acuerdo de la junta de propietarios adoptado por mayoría simple fuera dirigido a que en los supuestos en los que un comunero u ocupante de un inmueble aparcara su vehículo en forma inapropiada, en plaza de garaje que no fuera la suya, o en zona de elementos comunes, la junta autorizara a la presidencia y, por ende, al administrador de fincas, a que se recabe los servicios de una empresa privada, cuya mención ya se podría citar en el acuerdo para evitar que hubiera problemas en la empresa a elegir, o que esta luego no quisiera acudir, para que pueda entrar en la urbanización para sacar el vehículo y dejarlo en la vía pública debidamente estacionado. Ello, en primer lugar, tendría el refrendo de un acuerdo adoptado en junta, previamente incluido en el orden del día y que sería conocido por todos los comuneros, de tal manera que si alguien incumple la norma de aparcar en zonas prohibidas o en plazas que no sean las suyas, ya sería consciente de que su vehículo sería sacado de la comunidad. Además, en el acuerdo se haría constar que los gastos derivados de esta actuación de la grúa serían cargados en la deuda del comunero cargándosele en el importe del siguiente recibo. Ello tendría varias consecuencias, a saber:

1º.- Conocimiento del propietario de la existencia del acuerdo.

2º.- Su vigencia por no haber sido impugnado.

3º.- La viabilidad de la repercusión del gasto por estas incluido en el acuerdo aprobado y ejecutivo.

Con esta fórmula pensamos que tendría más eficacia disuasoria que la actual que apuesta tan solo por la esperanza del respeto a los demás que algunos parecen no tener en sus estatutos de vecinos y personas. Ello exigiría, también por último, que se acabaría informando luego al titular acerca del lugar donde está su vehículo. Por ello, en estos casos bien sería lo más adecuado dejar el vehículo estacionado en la vía pública en lugar permitido, siempre y cuando se hubiere hecho constar en la junta que la consecuencia del estacionamiento de los vehículos en lugar no autorizado, o en plazas que no les correspondan, habilitan al presidente para recabar los servicios de la grúa privada y que se dejaría este vehículo en la vía pública quedando exonerada la comunidad de las consecuencias del propio incumplimiento del comunero de acatar las prohibiciones de la comunidad de propietarios y que obligan a este a depositar el vehículo en la vía pública, con el consiguiente cargo de gastos en la cuenta de débito del comunero para con la comunidad. Los comuneros ya serán conscientes con su conducta incumplidora de cuáles son las consecuencias de su actuación, por lo que nada tendrían derecho a reclamar a la comunidad por ningún concepto, habida cuenta que cuando ejecutaron su conducta de aparcar mal su vehículo eran conscientes de lo que iba a ocurrir, no pudiendo alegar una conducta irregular de la comunidad, o que se ha utilizado su vehículo sin su consentimiento, por cuanto era sabedor de lo que ocurriría si adoptada tal conducta.

Lo que no puede llevarse a cabo es recabar los servicios de la grúa municipal, ni aunque se adopte el acuerdo en junta, ya que la policía local no puede intervenir en cuestiones que pertenezcan al ámbito de las relaciones privadas en las comunidades de propietarios.

Cordiales saludos.

Pablo Espinosa-Arroquia

Abogado

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