viernes, 20 de marzo de 2009

CONCEPTO Y REGIMENES

CONCEPTO Y REGIMENES.

La cooperación internacional como rasgo característico del Derecho Internacional Privado presenta una dimensión particularmente desarrollada en el ámbito del proceso.
El mismo principio que justifica el sector del Derecho Internacional Privado que da referencia al reconocimiento y ejecución de decisiones derivadas de un poder jurisdiccional extranjero, fundamenta un sector de Ordenamiento destinado a apaliar los inconvenientes que produce en el desarrollo del proceso la imposibilidad de ejercer el poder jurisdiccional fuera del territorio del propio Estado, con el fin de realizar determinados actos procesales.

Para llevar a buen término el proceso en el que se sustancia una situación del tráfico jurídico externo, es preciso analizar una serie de actos procesales, tales como las notificaciones, los emplazamientos o la práctica de la prueba, que deben tener lugar en el extranjero.

El Estado puede servirse en ocasiones, a tal efecto de sus agentes diplomáticos o funcionarios consulares acreditados en el extranjero, sin embargo, no siempre dichos actos procesales pueden realizarse sin la necesaria concurrencia o participación de las autoridades extranjeras, particularmente de sus órganos judiciales.

La cooperación internacional es absolutamente imprescindible y se ha materializado en un conjunto de de normas reguladoras de origen preferentemente convencional.

Descrita la justificación práctica de la institución, el fundamento teórico de la asistencia judicial internacional, entendida, en sentido estricto, como la cooperación entre autoridades de distintos Estados para la realización de actos procesales, se ha buscado en la propia existencia de una obligación internacional de cooperación, impuesta por una presunta costumbre internacional.

Es preciso negar la existencia de una obligación internacional de prestar asistencia judicial internacional basada en criterios de reciprocidad, en el mismo sentido con que se negaba dicha obligación en la aplicación del Derecho extranjero.

Es cierto que los Estados se avienen con normalidad para prestar dicha colaboración, por interés mutuo, pero en ningún caso detecta una convicción u opinio iuris acerca de la obligatoriedad de dicha conducta, que ha venido a ser regulada, desde el plano internacional, a través de textos internacionales de amplia proyección.

En el resto de la obligaciones impuestas por los Tratados internacionales suscritos, el Derecho interno tiende a facilitar la asistencia de forma disacional, atendiendo a principios de “cortesía internacional o propiamente de cooperación utilizando con cierta frecuencia los criterios de reciprocidad, como se detecta en los artículos 277 y 278 de la Lec.
Dentro de los actos procesales que requieren específicamente de la asistencia judicial internacional, destaca en primer lugar el régimen de notificaciones y comunicaciones que es preciso realizar en territorio extranjero.

La relación que presenta este acto procesal con los derechos fundamentales a la tutela judicial efectiva y a un proceso con las debidas garantías de defensa (artículo 24 CE), enfatiza la importancia y condiciona el propio contenido y alcance de los textos internacionales que facilitan la cooperación internacional, al tiempo que justifica la propia confianza y remisión de tales textos internacionales por parte de otros convenios internacionales.

En segundo término, la asistencia judicial internacional opera para solicitar de la autoridad extranjera la realización de un acto de instrucción, particularmente de la práctica de una prueba, dicha solicitud ha dado lugar a la institución de la comisión rogatoria, a través de la cual se evacua la petición.

Junto a estos actos, presenta un carácter más excepcional la asistencia judicial internacional dirigida a facilitar a las partes extranjeras la presentación en un procedimiento de actos procesales como la demanda o la petición del beneficio de justicia gratuita, que, por su menor relieve, no serán objeto de un tratamiento específico.

Por último, la asistencia judicial internacional presenta una manifestación característica del Derecho Internacional Privado, íntimamente relacionada con la aplicación judicial del Derecho extranjero, consistente en la petición a la autoridad extranjera de información acerca del Derecho de dicho estado, que debe ser aplicado por el juez del foro.

La asistencia judicial internacional se opera a través de dos distintos regímenes.

El Derecho autónomo español articula un régimen común que se contiene en los artículos 276 y 278 de la LOPJ y el artículo 300 de la Lec.

Sin embargo, dicho régimen presenta un carácter residual, siendo de aplicación prioritaria el régimen convencional.

El carácter residual del régimen común viene dado no sólo por la prevalencia de la reglamentación de origen convencional, sino porque, desde un punto de vista práctico, el gran desarrollo de las normas convencionales reduce la posibilidad real de aplicar el régimen común.

Existe en nuestro sistema, en consecuencia, un complejo tramado de normas convencionales sobre asistencia judicial internacional, no exento de problemas a la hora de delimitar sus ámbitos de aplicación e identificar la norma de aplicación procedente a la pretensión concreta.

Es de señalar, sin embargo, que los Tribunales españoles, más que en ningún otro sector del Derecho Internacional Privado, han procedido con cierta eficacia, no exenta de excepciones, a la interpretación y correcta aplicación de las normas convencionales que regulan la asistencia judicial internacional.

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