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A arbitragem de emergência como alternativa para solução de medidas urgentes na jurisdição privada

Centro de Arbitragem e Mediação Internacional

A arbitragem de emergência como alternativa para solução de medidas urgentes na jurisdição privada

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É relativamente comum que as partes signatárias de convenção de arbitragem se deparem com a necessidade de solicitação de medidas urgentes, de natureza cautelar, antes mesmo da constituição do Tribunal Arbitral.
Nessa hipótese, as partes habitualmente direcionam suas pretensões urgentes ao Poder Judiciário. No entanto, há outra conduta possível, para aqueles que não tenham interesse em submeter qualquer etapa de suas disputas ao Judiciário, já que optaram pela jurisdição privada.
Com efeito, algumas câmaras arbitrais (nacionais e internacionais) preveem, em seus regulamentos, a possibilidade de nomeação de “árbitro de emergência” (ou “árbitro de apoio”), para apreciar medidas urgentes.
O Regulamento de Arbitragem da Câmara de Comércio Internacional (CCI), por exemplo, estabelece procedimento específico para a nomeação, impugnação e atuação de árbitro de emergência (emergency arbitrator),1 possível antes da transmissão dos autos ao Tribunal Arbitral (ato que formaliza a constituição do Tribunal2). De acordo com o Regulamento da CCI, a decisão do árbitro de emergência terá a natureza de ordem processual, devendo ser proferida em até 15 dias, sem que tal decisão vincule em qualquer medida o Tribunal Arbitral posteriormente constituído (que poderá alterar, revogar ou anular a ordem3).
No plano nacional, exemplo de instituição a tratar da apreciação de medidas urgentes na jurisdição privada antes da formação do Tribunal Arbitral é a Câmara de Arbitragem do Mercado (CAM), que faculta às partes o requerimento de nomeação de árbitro de apoio, para decisão sobre “medidas conservatórias ou reparatórias revestidas de caráter de urgência, a fim de prevenir dano iminente ou prejuízo irreparável”. O Regulamento da CAM, contudo, apenas autoriza a nomeação de árbitro de apoio se a convenção de arbitragem contiver previsão expressa a esse respeito.4
De fato, a arbitragem de emergência tem se transformado em importante mecanismo de solução de medidas urgentes no âmbito da jurisdição privada, projetando para tal procedimento os mesmos atrativos da arbitragem em geral, tais como a rápida apreciação da questão (em contraposição à morosidade da jurisdição estatal, comum mesmo em casos de medidas liminares), a especialização do árbitro (ainda que, segundo os regulamentos acima citados, caiba ao presidente da câmara arbitral – e não às partes – nomear árbitro de emergência, dentre os que compõem os quadros da instituição) e a confidencialidade.
No entanto, a doutrina especializada tem apontado como um dos principais inconvenientes da adoção da arbitragem de emergência, no âmbito de arbitragens internacionais, a insegurança quanto à possibilidade de homologação e execução das ordens proferidas em tais procedimentos. Um dos principais argumentos invocados para questionar a executoriedade de tais decisões é o de que, por não terem natureza de sentença arbitral (não sendo, portanto, decisões definitivas), a elas não seriam aplicáveis, ao menos em tese, as disposições da Convenção de Nova York.5
De todo modo, a depender dos interesses das partes, a utilização do árbitro de emergência pode ser benéfica, sobretudo em arbitragens domésticas, para dirimir medidas urgentes, sendo conveniente que as partes interessadas em se valer de tal mecanismo expressem a sua vontade por ocasião da convenção de arbitragem, e, claro, conheçam de antemão como a câmara de arbitragem eleita regula o assunto.
_______
1 Vide Regulamento de Arbitragem da CCI – art. 29 (“árbitro de emergência”) e Apêndice V (“regras sobre o árbitro de emergência”). Por força do art. 29 (5), tais dispositivos somente são aplicáveis às partes signatárias da convenção de arbitragem (ou seus sucessores), quando esta preveja a aplicação do Regulamento da CCI e tenha sido invocada para o requerimento da medida urgente, ficando afastada a sua aplicação quando (i) a convenção seja anterior à data da entrada em vigor do Regulamento atual ou (ii) quando as partes tiverem convencionado excluir a sua incidência ou adotar outro procedimento pré-arbitral para solução de medidas urgentes: clique aqui.
2 E, portanto, nos termos do art. 19 da Lei 9.307/96, a instituição da arbitragem.
3 Não só por previsão expressa do Regulamento de Arbitragem da CCI, mas também porque, como esclarecem C.A. da Silveira Lobo e Rafael de Moura Rangel Ney, tendo a medida sido concedida “anteriormente à instauração da arbitragem, mediante, portanto, cognição sumária, (…) salta aos olhos o acerto de o árbitro, após examinar as razões das partes e sopesar a prova produzida, agindo por força de lei com a mesma diligência exigida do magistrado, manifestar-se em definitivo sobre a matéria.” (In: Arbitragem interna e internacional: questões de doutrina e da prática. Rio de Janeiro: Renovar, 2003, p. 256)
4 Vide Regulamento da CAM – art. 5.1 (“medidas de urgência antes de constituído o Tribunal Arbitral”): clique aqui.
5 Nesse sentido: clique aqui. No Brasil, Embora a questão ainda não tenha sido apreciada pelo STJ, há precedente do Supremo Tribunal Federal (STF), a quem anteriormente cabia a homologação de sentenças estrangeiras, no sentido de que decisões cautelares devem ser equiparadas a sentenças, para fins de homologação e cumprimento no território nacional (AgRg em CR nº 7.613-4, Rel. Min. Sepúlveda Pertence, j. 03.04.97). Para maiores informações, vide artigo “O cumprimento no Brasil de medidas cautelares concedidas no âmbito de procedimento arbitral estrangeiro”, que integra esta edição do Informativo.
Por Marcelo Levitinas e Renato Ferreira, respectivamente, sócio e associado do escritório Lobo & Ibeas Advogados.
Fonte: Migalhas, sexta-feira, 9 de outubro de 2015

 

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