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¿Libertad de testar?

La libertad de testar se desenvuelve en los preceptos de nuestro Código Civil decimonónico

En el quehacer diario de nuestros despachos, no es raro el caso del matrimonio, ya de cierta edad que, ante la pretensión de otorgar testamento, e informados del sistema de legítimas de nuestro Código Civil, se llevan una buena desilusión, al no poder  plasmar en aquel documento, que tanto valoran, sus verdaderas pretensiones. No aciertan a comprender como les está vedada la posibilidad de disponer de lo poco o mucho que han conseguido con esfuerzos y sacrificios a lo largo de su vida, a favor del sobreviviente o a favor de alguno de los hijos o descendientes o, incluso, de un extraño a la familia.

La casuística es muy variada. Matrimonio sin hijos, viviendo algún ascendiente de los cónyuges; matrimonio con varios hijos, sin que ninguno de ellos les preste la más mínima atención; matrimonio con varios hijos, de los cuales sólo uno “les hace caso y atiende”… Denominador común en todos ellos es el rígido sistema de legítimas del Código Civil, recogido en los artículos 806 y siguientes. En el primer caso reseñado, tropezamos con lo que dispone el artículo 809 pues, al concurrir el cónyuge viudo con los ascendientes del premuerto, a éstos les corresponde en concepto de legítima un tercio de la herencia. En los otros dos, tropezamos con lo dispuesto en el artículo 808, al disponer que constituye la legítima de los hijos y descendientes dos terceras partes del haber hereditario, si bien en su párrafo segundo, permite disponer de uno de los dos tercios a favor de hijos o descendientes, es decir, el tercio de mejora.

Justo es reconocer que se han producido algunas modificaciones en nuestro Código Civil, tendentes a moderar la rigidez del sistema de legítimas, tales como los artículos 808, párrafo tercero, 1.056 y 841 y, en cierta manera, el artículo 831. Cuestión distinta es lo que disponen sobre la materia las Legislaciones de algunas Comunidades Autónomas, tributarias de las antiguas Compilaciones Forales, siendo la máxima expresión en lo que se refiere a la libertad de testar  Aragón y Navarra y el caso del Fuero de Ayala.

Son variados los argumentos que se han esgrimido para defender el sistema de legítimas y para defender el de libertad de testar. A favor de las legítimas se invocaron criterios de unidad familiar, igualdad de todos los hijos, participación de todos ellos en la obtención de la riqueza y patrimonio familiar y otros. A favor de la libertad de testar, se invocaron criterios tales como que, si en vida una persona puede disponer de sus propiedades sin limitación, no se entiende como no lo puede hacer para después del fallecimiento, que la libertad de testar supone, por decirlo algún modo, un refuerzo de la autoridad de los padres sobre los hijos, de suerte que éstos procuren no desatender sus obligaciones para con sus progenitores, criterios políticos, al ser la libertad uno de los derechos fundamentales de la persona y otros.

Planteada la cuestión, se impone tomar partido por una u otra opción. Con estas escasas líneas, espero dejar al lector materia para que se decante por una u otra. En lo que al que al autor de las mismas se refiere, creo formar parte de una corriente mayoritaria en nuestra profesión, que ya tuvo ocasión de expresarse en algún seminario, partidaria de la libertad de testar. Por lo menos, libertad de disponer libremente por testamento a favor de algún hijo o descendiente, si bien podría plantearse la libertad absoluta de testar, incluso, a favor de personas extrañas a la familia.

Nuestro Código Civil nació a finales del siglo XIX . En aquellos tiempos la sociedad y, especialmente, la familia, tenían una estructura muy diferente a la de ahora. Había más vínculos familiares, padres e hijos vivían en una misma casa, todos contribuían al acervo familiar. En cambio, en los tiempos actuales, tarde o temprano, los padres se quedan solos o, como mucho, con algún hijo. Con esto no quiero decir que se produzca un desapego afectivo, pero es evidente que el ambiente actual no contribuye para nada al mantenimiento de esa “unidad familiar”. Es por eso que se impone reforzar las facultades dispositivas de los testadores, en orden a poder dar debido cumplimiento a sus verdaderos e íntimos deseos, que no son otros que dar justa y legítima retribución a quienes verdaderamente les han prestado ayuda, atenciones y cuidados, sobre todo, en la última fase de su vida.

Fernando Ovies Escrito por el oct 18 2011. Archivado bajo Derecho Privado, Jurídico, QAH Profesionales.





629 Comentarios por “¿Libertad de testar?”

  1. […] ¿Es conveniente otorgar testamento? var addthis_product = 'wpp-262'; var addthis_config = {"data_track_clickback":true,"data_track_addressbar":true};var addthis_options = "facebook,twitter,tuenti,email,print,,meneame,linkedin,google_plusone,myspace,digg,";if (typeof(addthis_share) == "undefined"){ addthis_share = {"templates":{"twitter":"{{title}} – Que Aprendemos Hoy {{url}} via @QAHcom"},"url_transforms":{"shorten":{"twitter":"bitly"}},"shorteners":{"bitly":{"login":"pjtrujillo","apiKey":"R_09bde2468b2275c66e7ba236003f5aa4"}}};}A lo largo de mi trayectoria profesional y, en no pocas ocasiones, he podido comprobar en las personas que acuden al despacho un miedo atávico al hecho de otorgar testamento. Entienden que es más bien propio de personas de avanzada edad que están en las postrimerías de su vida,  que eso de disponer su última voluntad suena tenebroso, “que no va conmigo”… Es por ello que con estas líneas me gustaría plantear la cuestión de si es conveniente o no otorgar testamento, si realmente va a ser útil, tanto para la persona que lo otorga, como para sus herederos. Ya traté en QAH el debate sobre la libertad de testar en nuestro ordenamiento. […]

  2. Mjacuaviva

    La Legítima, Pablo Gutiérrez Alvíz Notario.
    DESDE que ejerzo comonotario, hace ya casi veintiocho años, he podido comprobar cómo existe en nuestro Derecho Civil Común Español una institución que perturba a muchos padres ala hora de testar:la legítima. No es raro que comparezcan en mi despacho testadores, ya ancianos, que no desean dejar nada a unos hijos que, aunque no están incursos enlas extremas y vergonzantes causas de desheredación, no los tratan y ni siquiera ven por muy distintas razones (desdela enemistad hasta el mero abandono sentimental).

    La legítima se justificaba en el derecho histórico medieval como un derecho de alimentos para hijos que quedaban huérfanos siendo menores de edad, y posteriormente, cristalizó en nuestro decimonónico Código Civil como aquella porción de bienes dela que el testador no puede disponer por haberla reservadola ley a determinados herederos, llamados forzosos. Además ala legítima se le califica como intocable porque, en principio, no cabe gravarla ni condicionarla y, por supuesto, tampoco puede ser burlada en su cuantía a base de actos o negocios jurídicos quela minoren.

    El caso dela familia Cela resulta un claro ejemplo dela perversión del sistema legitimario. Después de convivir conla actual viuda casi catorce años, Camilo José Cela (CJC) muere el 17 de enero de 2002 bajo testamento abierto, otorgado en 1991, en el que instituyó heredera a Marina Castaño, su esposa, y reconocela legítima a su hijo, que entiende satisfecha conla donación que le hizo en vida del cuadro conocido como El Miró rasgado. Por otra parte, podría haber mejorado a su única nieta Camila pero, según aseguran, sólola vio un par de veces en su vida.

    El hijo de Cela, catedrático y escritor, tomó partido por su madre en el divorcio familiar a finales de los ochenta y confiesa que el último abrazo que dio a su padre fue en 1989 con motivo dela entrega del Premio Nobel. Luego fue observandola evolución personal y patrimonial del mismo con el que pleiteó a través dela Fundación CJC, ala que el gran escritor gallego seguía aportando bienes. Con este panoramala contienda judicial estaba asegurada:la legítima del hijo único asciende a dos tercios dela herencia (sin perjuicio de que un tercio queda gravado conla cuota legal usufructuaria dela viuda).

    Hace unos díasla Audiencia Provincial de Madrid ha dictado sentencia al respecto, ratificando casi en su integridadla de Primera Instancia y que, sin haber obtenido firmeza, relata cómo CJC y Marina Castaño formalizaron una serie de negocios jurídicos (donaciones encubiertas) conla finalidad de perjudicar los derechos legitimarios del hijo del primero. Desde una inicial aportación de derechos de autor a una sociedad mercantil que constituyen antes de casarse hasta lo que sería el prodigioso mes de junio de 1997 en el quela pareja, sucesivamente, los días 9, 12 y 23, aportaron bienes ala sociedad de gananciales, reconocieron préstamos ficticios, liquidaronla sociedad de gananciales, y ella constituye una nueva sociedad mercantil, casi unipersonal, que el 19 de septiembre del mismo año queda como cesionaria y titular de todala obra del Nobel mientras que CJC recibe, a cambio, una pequeña pensión y un crédito ficticio. Al fallecer el Nobel era un pobre de solemnidad.

    También incide enlas cuantiosas aportaciones de Cela a su fundación, que son objeto de reducción, porque perjudican el quantumdela legítima filial y rematala cuestión recordando que nadie puede dar por vía de donación más de lo que puede dar por testamento. Es decir, y simplificando, que Cela no podía disponer por donación en cuantía superior al tercio de libre disposición. Sila sentencia llega a ser firme, Cela Júnior (el legitimario, de 66 años de edad) recibirá más de 5 millones de euros (casi 4 dela marquesa viuda de Iría Flavia y uno y pico dela Fundación). Alberto Sáenz de Santamaría, amigo y fino jurista, ya anticipó en atinados artículos todo lo que iba a suceder.

    Parece evidente que CJC, al no poder desheredar a su hijo, optó por vaciar de contenido su herencia, beneficiando en vida a su esposa. Resulta patético que una figura de relevancia mundial tenga que acudir a ciertas operaciones fraudulentas porque todavía esté vigente una institución jurídica tan alejada dela realidad actual comola legítima. En pleno siglo XXI, con los variados tipos de familias,la longevidad de los progenitores, en los que los hijos son sexagenarios y los patrimonios familiares han sido creados por los propios testadores no parece pertinente mantener el sistema legitimario. Abogo porla libertad absoluta de testar, sin restricción alguna. Lo normal siempre será que los padres instituyan herederos a sus hijos protegiendo al cónyuge viudo. En mi opinión,la legítima se ha convertido en una especie de seguro del hijo ala herencia del padre cualquiera que sea el comportamiento de aquél con su progenitor.

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