Teoria Menor e Maior (Desconsideração da Personalidade)

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Você, muito provavelmente, já deve ter notado que a empresa é uma ficção – ou é possível tocarmos na empresa? A sentirmos? Conversarmos com ela? Muitas vezes, a empresa funciona como escudo /bloqueio contra a responsabilização de pessoas. Esses sujeitos devem seus fornecedores  não honram compromissos com clientes, dentre outras práticas. Mas podemos quebrar o escudo dessas pessoas por meio da desconsideração da personalidade jurídica. 

Código Civil:

Art. 50. Em caso de abuso da personalidade jurídica, caracterizado pelo desvio de finalidade ou pela confusão patrimonial, pode o juiz, a requerimento da parte, ou do Ministério Público quando lhe couber intervir no processo, desconsiderá-la para que os efeitos de certas e determinadas relações de obrigações sejam estendidos aos bens particulares de administradores ou de sócios da pessoa jurídica beneficiados direta ou indiretamente pelo abuso.

Primeiro ponto: O Código civil exige que haja o desvio de finalidade ou confusão patrimonial para que esteja configurado o abuso e seja feita a aplicação da desconsideração da personalidade jurídica. Se olharmos o Código de Defesa do Consumidor, por exemplo, encontraremos o seguinte:

Código de Defesa do Consumidor: 

Art. 28. O juiz poderá desconsiderar a personalidade jurídica da sociedade quando, em detrimento do consumidor, houver abuso de direito, excesso de poder, infração da lei, fato ou ato ilícito ou violação dos estatutos ou contrato social. A desconsideração também será efetivada quando houver falência, estado de insolvência, encerramento ou inatividade da pessoa jurídica provocados por má administração.

Analisando o CDC e o Código Civil, percebemos que o CDC não faz exigência de desvio de finalidade ou confusão patrimonial, isto é, suas exigências para a aplicação desta teoria são menores – razão pela qual dizemos que ele, o CDC, adota a teoria menor, e o CC, por ser mais exigente, adota a teoria maior da desconsideração da personalidade jurídica. 

Segundo ponto: O Código Civil fala de administradores ou de sócios da pessoa jurídica beneficiados direta ou indiretamente pelo abuso. Observe que o CC coloca tantos os administradores (não fala se eles são sócios também) quanto os sócios (que não sejam administradores) no mesmo barco. O Código de Defesa do Consumidor não fala de administradores. Para ser sincero, não fala de ninguém. Basta você procurar identificar os responsáveis no trecho de lei do CDC (Art. 28 acima). Recentemente, “O relator do recurso especial apresentado ao STJ, ministro Ricardo Villas Bôas Cueva, explicou que a teoria menor não exige prova de abuso de direito ou fraude, mas não dá margem para admitir a responsabilização de pessoas que não integram o quadro societário da empresa.”

Fonte: https://www.conjur.com.br/2021-jul-21/desconsideracao-pj-cdc-nao-estende-aos-administradores.

Ou seja, segundo o STJ, para que o juiz possa se valer da desconsideração da personalidade jurídica à ótica da teoria menor (e não sob a lupa da teoria maior), isto é, atacar os bens dos administradores, utilizando o Código de Defesa do Consumidor, eles (os administradores) deverão de ser simultaneamente sócios (e não apenas administradores da empresa). 

CEBRASPE (2018)

QUESTÃO ERRADA: O Código Civil de 2002 adotou a teoria menor: basta o mero prejuízo à parte para que a desconsideração da personalidade jurídica seja deferida.

CC adotou a teoria maior exigindo-se o requisito específico do abuso caracterizado pelo desvio de finalidade ou confusão patrimonial. A teoria menor, adotada pelo CDC e pela legislação ambiental, dispensa esses requisitos.

Teoria MAIOR

O Direito Civil brasileiro adotou a chamada teoria maior da desconsideração. Isso porque o art. 50 exige, além da insolvência, que se prove o desvio de finalidade (teoria maior subjetiva) ou a confusão patrimonial (teoria maior objetiva).

Deve-se provar:

1) Insolvência

2) Abuso da personalidade (desvio de finalidade ou confusão patrimonial)

Teoria MENOR

No Direito do Consumidor e no Direito Ambiental, adotou-se a teoria menor da desconsideração. Isso porque, para que haja a desconsideração da personalidade jurídica nas relações jurídicas envolvendo consumo ou responsabilidade civil ambiental, basta provar a insolvência da pessoa jurídica.

Deve-se provar apenas a insolvência.

Art. 4º da Lei n.° 9.605/98 (Lei Ambiental).

Art. 28, § 5º do CDC.

O encerramento irregular das atividades da empresa devedora autoriza, por si só, que se busque os bens dos sócios para pagar a dívida?

• Código Civil: NÃO

• CDC: SIM

• Lei Ambiental: SIM

• CTN: SIM

CEBRASPE (2021);

QUESTÃO ERRADA: A desconsideração da personalidade jurídica, a partir da teoria maior, exige a comprovação do abuso, o que se presume ocorrido caso haja encerramento irregular das atividades das pessoas jurídica.

CEBRASPE (2019):

QUESTÃO CERTA: No direito pátrio, as hipóteses de desconsideração da personalidade jurídica abarcam duas teses majoritariamente aceitas pela doutrina e pela jurisprudência dominantes. Elas se diferenciam precipuamente quanto aos requisitos para que um órgão jurisdicional possa desconsiderar a personalidade jurídica de uma sociedade personificada, de modo a atingir o patrimônio dos seus sócios para o pagamento de uma obrigação inadimplida: a primeira considera necessário que tenha ocorrido abuso de personalidade jurídica, caracterizado por desvio de finalidade ou confusão patrimonial; a segunda teoria considera que, para a desconsideração da personalidade, basta a apresentação de mera prova de insolvência da pessoa jurídica para o pagamento de suas obrigações, independentemente da existência de desvio de finalidade ou de confusão patrimonial. Considerando o entendimento doutrinário majoritário e a jurisprudência dominante do STJ, assinale a opção que indica, respectivamente, a denominação dada à segunda teoria de que trata o texto apresentado e o ramo do direito ao qual ela se aplica no ordenamento jurídico brasileiro excepcionalmente:

(A) teoria menor da desconsideração – direito civil

Incorreta. O direito civil adota a teoria maior (mais requisitos).

(B) teoria menor da desconsideração – direito ambiental

Correta. O direito ambiental, em caso de dano ambiental, a exemplo do direito do consumidor, adota a teoria menor.

Desconsideração da Personalidade Jurídica – Art. 4º da Lei de Crimes Ambientais – Poderá ser desconsiderada a pessoa jurídica sempre (teoria menor) que sua personalidade for obstáculo ao ressarcimento de prejuízos causados à qualidade do meio ambiente.

(C) teoria maior objetiva da desconsideração – direito civil

Incorreta. A primeira teoria é a maior (direito civil); a segunda é a menor (ambiental e consumidor).

(D) teoria maior subjetiva da desconsideração – direito do consumidor

Incorreta. O direito do consumidor adota a teoria menor. Nada disso de maior subjetiva.

(E) teoria maior objetiva da desconsideração – direito do consumidor

Incorreta. O direito do consumidor adota a teoria menor (menos requisitos).

O que é teoria maior Subjetiva e Objetiva? Nada mais é do uma nomenclatura da dada as hipóteses de abuso de poder ensejadoras da desconsideração da personalidade jurídica. São elas:

i. Teoria Maior Subjetiva da Desconsideração – desconsideração da personalidade jurídica baseada no desvio de finalidade. Caracterizado pelo ato intencional dos sócios de fraudar terceiros com o uso abusivo da personalidade jurídica.

ii. Teoria Maior Objetiva da Desconsideração – desconsideração da personalidade jurídica baseada na confusão patrimonial. Demonstrada pela inexistência, no campo dos fatos, de separação entre o patrimônio da pessoa jurídica e os de seus sócios.

Fonte – STJ no REsp 1325663 / SP.

CEBRASPE (2015):

QUESTÃO ERRADA: De acordo com a teoria maior, é suficiente que haja prejuízo ao credor não negocial para que seja cabível a desconsideração da personalidade jurídica da sociedade empresária.

INCORRETA. Conceito é referente à teoria menor.

CEBRASPE (2013):

QUESTÃO ERRADA: Para a comprovação do requisito da confusão patrimonial, exige-se demonstração de má-fé, elemento subjetivo, dos sócios.

ERRADA. O art. 50 do Código Civil, segundo doutrina majoritária, adotou a teoria maior objetiva da desconsideração da pessoa jurídica. Sendo, portanto, de pouca importância o requisito subjetivo.

FUNIVERSA (2015):

QUESTÃO ERRADA: No Código Civil brasileiro, adota-se a teoria menor da desconsideração da pessoa jurídica, ao passo que, no Código de Defesa do Consumidor (CDC), é adotada a teoria maior da desconsideração.

Na verdade, é o contrário. O CC adota a Teoria Maior (“maior dificuldade”) e o CDC adota a Teoria Menor (“menor dificuldade”).

CC – TEORIA MAIOR – exige-se o requisito específico do abuso caracterizado pelo desvio de finalidade ou confusão patrimonial

CDC – TEORIA MENOR – mais fácil de ser aplicada, não exige a demonstração de tal requisito.

CEBRASPE (2021):

QUESTÃO CERTA: A desconsideração da personalidade jurídica ainda que com fundamento na teoria menor não pode atingir o patrimônio pessoal de membros do conselho fiscal da empresa sem que haja mínima presença de indícios de que estes tenham contribuído ao menos culposamente e com desvio de função para prática de atos de administração.

“A desconsideração da personalidade jurídica fundamentada no parágrafo 5º do artigo 28 do Código de Defesa do Consumidor não pode atingir o patrimônio pessoal de membros do conselho fiscal sem que haja indícios de que tenham participado da gestão e contribuído, ao menos de forma culposa, e com desvio de função, para a prática de atos de administração”.

Fonte: Conjur.

“O parágrafo 5º do artigo 28 consagra a chama teoria menor da desconsideração da personalidade jurídica, cujo único pressuposto de aplicação é a insatisfação do credor”.

Fonte: http://www.mp.go.gov.br/portalweb/hp/4/docs/da_aplicabilidade_do_artigo_28_do_cdc.pdf.

CEBRASPE (2013):

QUESTÃO ERRADA: Conforme entendimento do STJ, em relação à desconsideração da personalidade jurídica, o ordenamento jurídico pátrio adotou a denominada teoria maior da desconsideração.

Justificativa da banca: “Apesar de a adoção da teoria maior da desconsideração ser a regra geral no direito brasileiro, não se pode afirmar, no contexto delimitado pelo item, que o ordenamento jurídico pátrio a adotou plenamente, pois, houve casos, como no CDC, em que foi adotada a teoria menor da desconsideração”. 

CEBRASPE (2013):

QUESTÃO CERTA: A teoria menor da desconsideração da personalidade jurídica centra-se no simples prejuízo do credor para afastar a autonomia patrimonial da sociedade empresarial.

Teoria menor: basta o prejuízo.

Teoria maior: deve haver prejuízo + intenção de fraude e de prejuízo.

CEBRASPE (2012):

QUESTÃO ERRADA: A aplicação da técnica da desconsideração da personalidade jurídica com a finalidade de atingir o patrimônio de todos os envolvidos é permitida somente nas hipóteses de fraude cometida com o objetivo de desviar patrimônio de sociedade falida, em prejuízo da massa de credores, por meio de complexas formas societárias e de simulação de solvência da sociedade.

A desconsideração da personalidade jurídica é permitida em caso de abuso da personalidade jurídica, caracterizado pelo desvio da finalidade ou confusão patrimonial (art. 50 do CC/02), pela teoria maior da desconsideração, adotada pelo CC/02.

CEBRASPE (2023):

QUESTÃO ERRADA: O Código de Defesa do Consumidor (Lei n.º 8.078/1990) prevê a possibilidade de desconsideração da personalidade jurídica quando a personalidade da pessoa jurídica for, de alguma forma, obstáculo ao ressarcimento de prejuízos causados aos consumidores, bem como a possibilidade de extensão da responsabilidade ao administrador não sócio.  

Não está correta, porque o CDC não prevê essa extensão para administradores não sócios, apesar de adotar a teoria menor da desconsideração.

CEBRASPE (2023):

QUESTÃO ERRADA: A excepcionalidade do pedido de desconsideração da personalidade jurídica decorre do fato de a autonomia patrimonial das pessoas jurídicas ser um instrumento licito de alocação e segregação de riscos, prevalecendo no ordenamento jurídico brasileiro a adoção da teoria maior, devendo esta ser adotada para todos os casos de desconsideração.

ERRADO, na seara do direito do consumidor e do direito do trabalho, por exemplo, prevalece a aplicação da teoria menor prevista no art. 28, § 5°, do CDC.

FGV (2023):

QUESTÃO ERRADA: A Sociedade Ômicron Comércio de Alimentos e Bebidas Ltda., nos últimos cinco anos, transferiu ativos para seus dois únicos sócios, sem nenhuma espécie de contraprestação. A transferência corresponde a setenta e cinco por cento do patrimônio líquido da sociedade, o que conduziu à inadimplência de diversas obrigações, incluindo um contrato de mútuo bancário. Diante da situação narrada, assinale a afirmativa corret a: O Código Civil brasileiro adota a teoria maior para fins de desconsideração da personalidade jurídica, que pode ser reconhecida de ofício pelo juiz no caso hipotético do enunciado.

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De fato, o Código Civil adota a Teoria Maior da Desconsideração da Personalidade Jurídica no caput do art. 50. A alternativa está errada pois diante do caso narrado (confusão patrimonial) o juízo só pode desconsiderar a personalidade jurídica se houver requerimento da parte, ou do Ministério Público quando lhe couber intervir no processo e não de ofício.

FGV (2023):

QUESTÃO ERRADA:A Sociedade Ômicron Comércio de Alimentos e Bebidas Ltda., nos últimos cinco anos, transferiu ativos para seus dois únicos sócios, sem nenhuma espécie de contraprestação. A transferência corresponde a setenta e cinco por cento do patrimônio líquido da sociedade, o que conduziu à inadimplência de diversas obrigações, incluindo um contrato de mútuo bancário. Diante da situação narrada, assinale a afirmativa correta: A desconsideração da personalidade jurídica no caso da sociedade Ômicron depende da existência de grupo econômico. 

Importante destacar que a Teoria Menor está prevista notadamente no art. 28, caput e parágrafo 5º do Código de Defesa do Consumidor e no art. 4º da lei nº 9605/98 (Proteção ao Meio Ambiente).

Art. 50, § 4º do Código Civil = A mera existência de grupo econômico sem a presença dos requisitos de que trata o caput deste artigo (desvio de finalidade ou confusão patrimonial) não autoriza a desconsideração da personalidade da pessoa jurídica.

FGV (2023):

QUESTÃO ERRADA: A Sociedade Ômicron Comércio de Alimentos e Bebidas Ltda., nos últimos cinco anos, transferiu ativos para seus dois únicos sócios, sem nenhuma espécie de contraprestação. A transferência corresponde a setenta e cinco por cento do patrimônio líquido da sociedade, o que conduziu à inadimplência de diversas obrigações, incluindo um contrato de mútuo bancário. Diante da situação narrada, assinale a afirmativa correta.

Não se aplica, pois basta a configuração do abuso da personalidade jurídica e o preenchimento dos requisitos do caput do art. 50 do CC para que o juízo possa desconsiderar a personalidade jurídica, não se falando em “vulnerabilidade jurídica da sociedade”.

FGV (2023):

QUESTÃO ERRADA: A Sociedade Ômicron Comércio de Alimentos e Bebidas Ltda., nos últimos cinco anos, transferiu ativos para seus dois únicos sócios, sem nenhuma espécie de contraprestação. A transferência corresponde a setenta e cinco por cento do patrimônio líquido da sociedade, o que conduziu à inadimplência de diversas obrigações, incluindo um contrato de mútuo bancário. Diante da situação narrada, assinale a afirmativa correta.

O caput do art. 50 do CC preceitua que o juízo pode desconsiderar a personalidade jurídica “para que os efeitos de certas e determinadas relações de obrigações sejam estendidos aos bens particulares de administradores ou de sócios da pessoa jurídica beneficiados direta ou indiretamente pelo abuso”.

FGV (2023):

QUESTÃO ERRADA: A teoria menor da desconsideração da personalidade jurídica é aplicada quando: for exigida do credor a prova de fraude ou de abuso do direito imputados ao sócio administrador da sociedade, conforme previsto no Art. 50 do Código Civil.

Está incorreta, pois a prova da fraude ou abuso do direito importa na aplicação da teoria maior da desconsideração da personalidade jurídica, conforme art. 50, caput, do CC: “Em caso de abuso da personalidade jurídica, caracterizado pelo desvio de finalidade ou pela confusão patrimonial, pode o juiz, a requerimento da parte, ou do Ministério Público quando lhe couber intervir no processo, desconsiderá-la para que os efeitos de certas e determinadas relações de obrigações sejam estendidos aos bens particulares de administradores ou de sócios da pessoa jurídica beneficiados direta ou indiretamente pelo abuso.”.

Fonte: Estratégia Concursos.

FGV (2023):

QUESTÃO ERRADA: A teoria menor da desconsideração da personalidade jurídica é aplicada quando: o credor comprova a existência de confusão patrimonial, desde que esta seja reconhecida por meio da obtenção ilícita de valores no patrimônio do administrador sócio da sociedade.

Está incorreta, pois a exigência de que o credor comprove a confusão patrimonial reconhecida por meio da obtenção ilícita de valores no patrimônio do administrador sócio da sociedade, envolve a aplicação da teoria maior da desconsideração da personalidade jurídica, conforme art. 50, §2º, II, do CC: ” Entende-se por confusão patrimonial a ausência de separação de fato entre os patrimônios, caracterizada por: […] II – transferência de ativos ou de passivos sem efetivas contraprestações, exceto os de valor proporcionalmente insignificante; […]”.

Fonte: Estratégia Concursos.

FGV (2023):

QUESTÃO ERRADA: A teoria menor da desconsideração da personalidade jurídica é aplicada quando: com base no Art. 50 do Código Civil, o administrador que não integra o quadro societário da empresa for pessoalmente responsabilizado pelos danos sofridos pelos credores da pessoa jurídica.

Está incorreta, pois só cabe a responsabilização do administrador não sócio na desconsideração da personalidade jurídica nos casos de aplicação da teoria maior da responsabilidade, conforme expressa redação do art. 50, caput, do CC. Nesse sentido, veja-se o acórdão citado no Informativo 754 do STJ: “RECURSO ESPECIAL (ART. 105, INC. III, “a” e “c”, da CRFB/88) – AUTOS DE AGRAVO DE INSTRUMENTO NA ORIGEM – INCIDENTE DE DESCONSIDERAÇÃO DA PERSONALIDADE JURÍDICA ACOLHIDO PELAS INSTÂNCIAS ORDINÁRIAS. INSURGÊNCIA DOS ADMINISTRADORES NÃO-SÓCIOS. TEORIA MENOR DA DESCONSIDERAÇÃO DA PERSONALIDADE JURÍDICA – CÓDIGO DE DEFESA DO CONSUMIDOR – AUSÊNCIA DE PREVISÃO NORMATIVA ESPECÍFICA PARA APLICAÇÃO DO § 5º DO ART. 28 AOS ADMINISTRADORES NÃO-SÓCIOS – IMPOSSIBILIDADE DE INTERPRETAÇÃO EXTENSIVA. […] Com efeito, dada especificidade do parágrafo em questão, e as consequências decorrentes de sua aplicação – extensão da responsabilidade obrigacional -, afigura-se inviável a adoção de um interpretação extensiva, com a atribuição da abrangência apenas prevista no artigo 50 do Código Civil, mormente no que concerne à responsabilização de administrador não sócio. […] (REsp n. 1.860.333/DF, relator Ministro Marco Buzzi, Quarta Turma, julgado em 11/10/2022, DJe de 27/10/2022.)

Fonte: Estratégia Concursos.

FGV (2023):

QUESTÃO ERRADA: A teoria menor da desconsideração da personalidade jurídica é aplicada quando: reconhecida a responsabilização dos sócios da pessoa jurídica, ainda que não haja insolvência da pessoa jurídica nem fraude comprovada, o patrimônio dos sócios for suficiente para pagar as dívidas dos credores daquela.

Está incorreta, pois a hipótese descrita é de corresponsabilidade solidária dos sócios por dívida societária, o que dispensa a desconsideração da personalidade jurídica. Pode-se citar como exemplos: a) o trespasse de estabelecimento empresarial, se o alienante deixar de explorar seu objeto (art. 133, I, do CTN: “Art. 133. A pessoa natural ou jurídica de direito privado que adquirir de outra, por qualquer título, fundo de comércio ou estabelecimento comercial, industrial ou profissional, e continuar a respectiva exploração, sob a mesma ou outra razão social ou sob firma ou nome individual, responde pelos tributos, relativos ao fundo ou estabelecimento adquirido, devidos até à data do ato: I – integralmente, se o alienante cessar a exploração do comércio, indústria ou atividade;”); b) dívidas que envolvem o valor pela integralização do capital social não efetivada (art. 1.052 do CC: “Na sociedade limitada, a responsabilidade de cada sócio é restrita ao valor de suas quotas, mas todos respondem solidariamente pela integralização do capital social.”).

Fonte: Estratégia Concursos.

FGV (2023):

QUESTÃO CERTA: A teoria menor da desconsideração da personalidade jurídica é aplicada quando: o consumidor demonstra o estado de insolvência do fornecedor ou a sua personalidade jurídica representa obstáculo ao ressarcimento dos seus danos, conforme o Art. 28, parágrafo 5°, do Código de Defesa do Consumidor.

Está correta, pois o art. 28, §5º, do CDC, conforme acórdão acima citado, positiva uma das hipóteses de aplicação da teoria menor da desconsideração da personalidade jurídica, justamente porque não se exige a prova de fraude, abuso da personalidade ou confusão patrimonial (teoria maior), bastando prova de insolvência do devedor original. Veja-se o texto legal: “Também poderá ser desconsiderada a pessoa jurídica sempre que sua personalidade for, de alguma forma, obstáculo ao ressarcimento de prejuízos causados aos consumidores.”.

Fonte: Estratégia Concursos.

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