A contagem dos prazos processuais em dias úteis e o Juizado Especial

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Novo CPC – A contagem dos prazos processuais em dias úteis e o Juizado Especial

A forma de contagem dos prazos processuais costuma gerar muitas dúvidas tanto em pessoas leigas como em operadores e profissionais do direito. Com o objetivo de ajudar a esclarecer essas dúvidas, fiz aqui uma compilação das regras de contagem de prazos importantes na Justiça do Trabalho.

Para entender a contagem dos prazos, são determinadas algumas regras:

1ª regra: contam-se os prazos a partir daciência/conhecimento pela parte de certa movimentação processual. Exemplos: recebimento da notificação, publicação do edital, etc. Tal regra encontra previsão no artigo 774 daConsolidação das Leis do Trabalho (CLT):

Consolidação das Leis do Trabalho, 1943.

Art. 774 – Salvo disposição em contrário, os prazos previstos neste Título contam-se, conforme o caso, a partir da data em que for feita pessoalmente, ou recebida a notificação, daquela em que for publicado o edital no jornal oficial ou no que publicar o expediente da Justiça do Trabalho, ou, ainda, daquela em que for afixado o edital na sede da Junta, Juízo ou Tribunal.

2ª regra: contam-se os prazos excluindo o dia do começo e incluindo o dia do vencimento, ou seja, a contagem será iniciada no primeiro dia útil subsequente ao dia da ciência/conhecimento. Entendimento do artigo 775 daCLT:

Consolidação das Leis do Trabalho, 1943.

Art. 775 – Os prazos estabelecidos neste Título contam-se com exclusão do dia do começo e inclusão do dia do vencimento, e são contínuos e irreleváveis, podendo, entretanto, ser prorrogados pelo tempo estritamente necessário pelo juiz ou tribunal, ou em virtude de força maior, devidamente comprovada.

3ª regra: se o dia do conhecimento/ciência ou o dia do início da contagem do prazo cair em dia não útil, o início da contagem se prorrogará para o primeiro dia útil subsequente, conforme entendimento das Súmulas 1 e 262, I do Tribunal Superior do Trabalho (TST) e 310 do Supremo Tribunal Federal (STF):

Súmula nº 1 do TST

PRAZO JUDICIAL (mantida) – Res. 121/2003, DJ 19, 20 e 21.11.2003

Quando a intimação tiver lugar na sexta-feira, ou a publicação com efeito de intimação for feita nesse dia, o prazo judicial será contado da segunda-feira imediata, inclusive, salvo se não houver expediente, caso em que fluirá no dia útil que se seguir.

Súmula nº 262 do TST

PRAZO JUDICIAL. NOTIFICAÇÃO OU INTIMAÇÃO EM SÁBADO. RECESSO FORENSE. (redação do item II alterada na sessão do Tribunal Pleno realizada em 19.05.2014) – Res. 194/2014, DEJT divulgado em 21, 22 e 23.05.2014

I – Intimada ou notificada a parte no sábado, o início do prazo se dará no primeiro dia útil imediato e a contagem, no subsequente.

Súmula nº 310 do STF

Quando a intimação tiver lugar na sexta-feira, ou a publicação com efeito de intimação for feita nesse dia, o prazo judicial terá início na segunda-feira imediata, salvo se não houver expediente, caso em que começará no primeiro dia útil que se seguir.

4ª regra: se o dia do vencimento (término do prazo) cair em dia não útil, o encerramento do prazo se prorrogará para o primeiro dia útil subsequente. Esta regra está disposta noparágrafo único do artigo 775 da CLT:

Consolidação das Leis do Trabalho, 1943.

Art. 775 – Parágrafo único – Os prazos que se vencerem em sábado, domingo ou dia feriado, terminarão no primeiro dia útil seguinte.

5ª regra: os prazos processuais são contínuos e irreleváveis (art. 775, caput, CLT). Prazos irreleváveis, são os prazos que não se interrompem nos feriados. Com efeito, dia não útil no meio da contagem será computado normalmente.

6ª regra: os prazos poderão ser prorrogados, pelo tempo estritamente necessário, mediante determinação do juiz ou do tribunal, ou em caso de força maior devidamente comprovada (art. 775, caput, CLT).

Para melhor visualização das regras citadas, apresentamos os esquemas seguintes, sempre considerando um prazo de 05 (cinco) dias:

A contagem de prazos na Justia do Trabalho

A contagem de prazos na Justia do Trabalho

A contagem de prazos na Justia do Trabalho

A contagem de prazos na Justia do Trabalho

A contagem de prazos na Justia do Trabalho

A contagem de prazos na Justia do Trabalho

Além das regras básicas citadas acima, não podemos estudar os prazos processuais da Justiça do Trabalho sem falar nas férias coletivas e no recesso forense. No processo civil, a superveniência das férias leva à suspensão dos prazos, segundo preleciona o artigo 179 do Código de Processo Civil:

Código de Processo Civil, 1973.

Art. 179. A superveniência de férias suspenderá o curso do prazo; o que Ihe sobejar recomeçará a correr do primeiro dia útil seguinte ao termo das férias.

No mesmo sentido, o Tribunal Superior do Trabalho editou a parte II, da súmula 262, que estabelece que as férias coletivas dos Ministros do Tribunal Superior do Trabalho suspendem os prazos recursais:

Súmula nº 262 do TST

PRAZO JUDICIAL. NOTIFICAÇÃO OU INTIMAÇÃO EM SÁBADO. RECESSO FORENSE. (redação do item II alterada na sessão do Tribunal Pleno realizada em 19.05.2014) – Res. 194/2014, DEJT divulgado em 21, 22 e 23.05.2014

[…]

II – O recesso forense e as férias coletivas dos Ministros do Tribunal Superior do Trabalho suspendem os prazos recursais. (ex-OJ nº 209 da SBDI-1 – inserida em 08.11.2000)

Noutra esfera, o inciso XII, do artigo 93, da Constituição Federal, com a redação dada pela Emenda Constitucional45/2004, proibiu as férias coletivas nos juízos (1º grau) e tribunais de 2º grau:

Constituição Federal, 1988.

Art. 93. Lei complementar, de iniciativa do Supremo Tribunal Federal, disporá sobre o Estatuto da Magistratura, observados os seguintes princípios: […]; XII a atividade jurisdicional será ininterrupta, (sic) sendo vedado férias coletivas nos juízos e tribunais de segundo grau, funcionando, nos dias em que não houver expediente forense normal, juízes em plantão permanente; […].

Porém, o texto constitucional não proibiu expressamente o recesso forense, o que gerou grande divergência interpretativa na doutrina e jurisprudência.

Contudo, considerando que a redação da parte II, da Súmula 262, do Tribunal Superior do Trabalho, é posterior à Emenda Constitucional 45/2004, é possível afirmar que o Tribunal Superior do Trabalho entende haver compatibilidade entre o recesso forense e o novo texto constitucional, sendo que aquele suspenderá os prazos em curso.

No processo do trabalho, há grande divergência relacionada ao recesso forense anual (20 de dezembro à 06 de janeiro) previsto no inciso I, do artigo 62, da Lei 5.010/66:

Lei 5.010, 30 de maio de 1966.

Art. 62. Além dos fixados em lei, serão feriados na Justiça Federal, inclusive nos Tribunais Superiores: I – os dias compreendidos entre 20 de dezembro e 6 de janeiro, inclusive; […].

Apesar do texto legal determinar que o período é considerado feriado, surgiram duas correntes de interpretação do texto legal: para a primeira corrente, o recesso forense deve ser equiparado às férias (suspendendo a contagem dos prazos recursais, nos termos do artigo 179 do Código de Processo Civil); para a segunda corrente, o recesso forense deve ser equiparado aos feriados (não suspendendo o prazo processual).

Assim, caso considerado o recesso como férias, o prazo iniciado antes daquele, seria suspenso e continuaria a contar após o retorno às atividades:

A contagem de prazos na Justia do Trabalho

Lado outro, caso o recesso fosse considerado como feriado, o prazo se contaria em dias corridos, porém havendo término durante o recesso, a data do vencimento se prorrogaria para o primeiro dia útil subsequente (art. 775, CLT):

A contagem de prazos na Justia do Trabalho

Visando dirimir o conflito, o Tribunal Superior do Trabalho editou a segunda parte da Súmula 262, já colacionada acima, equiparando o recesso às férias e levando à suspensão dos prazos.

Por fim, quanto aos processos eletrônicos, devemos relembrar dos dizeres da Lei 11.419/2006 (Lei de Informatização do Processo Judicial):

Lei nº 11.419, de 19 de dezembro de 2006.

Art. 3º Consideram-se realizados os atos processuais por meio eletrônico no dia e hora do seu envio ao sistema do Poder Judiciário, do que deverá ser fornecido protocolo eletrônico.

Parágrafo único. Quando a petição eletrônica for enviada para atender prazo processual, serão consideradas tempestivas as transmitidas até as 24 (vinte e quatro) horas do seu último dia.

Art. 4º – […].

§ 3º Considera-se como data da publicação o primeiro dia útil seguinte ao da disponibilização da informação no Diário da Justiça eletrônico.

§ 4º Os prazos processuais terão início no primeiro dia útil que seguir ao considerado como data da publicação.

Portanto, no caso dos processos eletrônicos, considera-se data de publicação o primeiro dia útil subsequente ao da disponibilização da informação no Diário da Justiça. A contagem inicia no primeiro dia útil subsequente, vejamos:

A contagem de prazos na Justia do Trabalho

Autoria de: FARACO, Marcela. A contagem de prazos na Justiça do Trabalho. MF – Direito e Advocacia, 29 out. 2014. Disponível em: http://marcelafaraco.jusbrasil.com.br/publicacoes.


Contudo, a novidade da contagem dos prazos em dias úteis introduzida pelo novo CPC não agradou aqueles que defendem a celeridade, a economia processual e a razoável duração do processo como princípios basilares da lei 9.099/95.
Tanto que os magistrados integrantes da diretoria e comissões do Fórum Nacional de Juizados Especiais após grande deliberação elaboraram nota técnica afirmando que os prazos processuais contados em dias úteis não se aplicam aos processos de competência dos Juizados Especiais.
A norma técnica 1/16 destaca que os Juizados Especiais possuem critérios específicos que devem orientar os processos judiciais e que são incompatíveis com a contagem dos prazos processuais somente em dias uteis, são eles: oralidade, simplicidade, informalidade, economia processual e celeridade.
Destaca, também, que a contagem dos prazos processuais em dias úteis afronta o princípio constitucional da razoável duração do processo, o que afasta a possibilidade de ser aplicada aos processos em trâmite perante os Juizados Especiais.
Contudo, a posição estabelecida no Fórum Nacional de Juizados Especiais não é obrigatória e o TJ/DF manifestou sua concordância com a regra da contagem dos prazos processuais em dias úteis nos termos estabelecidos pelo novo CPC, considerando principalmente a lacuna contida na lei dos juizados especiais e a aplicação subsidiária da lei processual civil.
O fato é que há grande controvérsia a respeito do assunto nos Tribunais Estaduais, o que gera grande insegurança aos operadores do direito. O ideal é que os advogados assumam uma posição conservadora e adotem a nota técnica 1/16 expedida pelo Fórum Nacional dos Juizados Especiais, ou seja, continuem aplicando os prazos em dias corridos para defesas, recursos e demais manifestações perante os Juizados Especiais, evitando, dessa maneira, riscos e eventuais perdas de prazo.

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