La Sentencia del Tribunal Superior de Justicia de Madrid, Sala de lo Civil y Penal, Sección Primera, de 10 de mayo de 2022 (ponente: Celso Rodríguez Padrón) desestima una acción de anulación contra un laudo arbitral dictado por árbitro único en el seno de la Corte de Arbitraje del Iltre. Colegio de Abogados de Madrid y su Laudo aclaratorio. De acuerdo con esta decisión, tras la “ineludible la cita de las Sentencias del Tribunal Constitucional 46/2020, de 15 de junio de 2020, 17/2021, de 15 de febrero de 2021, y 65/2021, de 15 de marzo de 2021”:
“(…) EL TSC confirma un laudo descartando que carece de motivación (por ser arbitraria), vulnera el principio de contradicción, e incurre en incongruencia extra petita.
“(…) Todos los motivos sobre los que se construye la demanda se incardinan -desde la lectura que del laudo lleva a cabo la parte que promueve esta acción de nulidad- dentro del concepto de orden público, que la mercantil actora considera vulnerado desde múltiples facetas. Pese a resultar tan conocida la acuñada doctrina en torno a la delimitación de la causa prevista en el art. 41.1º.f) LA, recordaremos -una vez más- sus parámetros marco, reiterando que no pueden ser objeto de esa vis expansiva tantas veces asumida cuando se ocupa la posición procesal de demandante (…)”.
“(…) Cabe, pues, exigir la motivación del laudo establecida en el art. 37.4º LA, pues las partes tienen derecho a conocer las razones de la decisión. En consecuencia, en aquellos supuestos en los que el árbitro razona y argumenta su decisión, habrá visto cumplida la exigencia de motivación, sin que el órgano judicial pueda revisar su adecuación al derecho aplicable o entrar a juzgar sobre la correcta valoración de las pruebas, por más que de haber sido él quien tuviera encomendado el enjuiciamiento del asunto, las hubiera razonado y valorado de diversa manera’ ( STC 65/2021 FJ 5). Abordaremos por el orden en que se incluyen en la demanda, los diferentes motivos esgrimidos a la luz de los parámetros generales que acabamos de exponer”.
“(…) Dentro de la vertiente de vulneración del orden público procesal se nos dice que el laudo no ha respetado el principio de contradicción, y que se basa en un hecho carente de prueba. Sin duda alguna el principio de contradicción se erige como uno de los fundamentos incuestionables de la validez del procedimiento arbitral. La propia Ley de Arbitraje, en su art. 24 protege expresamente los principios de igualdad, audiencia y contradicción para las partes, de modo que la palmaria infracción de cualquiera de ellos abocaría al planteamiento de la nulidad, siempre -no sobra decirlo- que se acreditase que con ello se generó indefensión material para la parte que alega semejante quiebra. El procedimiento arbitral, por autónomo que resulte en múltiples aspectos respecto de las exigencias inherentes a la tutela judicial efectiva, no puede eludir el respeto a los principios básicos que rigen la relación entre partes, y asimismo la de éstas con el órgano arbitral, dotándose así de un contexto de garantías que redundan en la propia credibilidad del arbitraje como cauce solvente de solución de conflictos. En un Estado de Derecho no podría consentirse (ni mucho menos establecerse por Ley) un cauce de resolución de conflictos, generalmente orientado a proporcionar una solución jurídica a la controversia que se suscita sobre materias disponibles, sin garantía de respeto a los derechos fundamentales. El de defensa, lo es. 1.- En cualquier caso, y partiendo de tan básica premisa, no alcanzamos a comprender en qué sentido ha podido verse conculcado el principio de contradicción (posibilidad de discutir las posiciones de contrario) en el supuesto analizado. Todo se centra -según la presente demanda- en que la compañía aseguradora sostuvo la existencia de otras pólizas de seguro a favor de la asegurada, y propuso al árbitro que requiriese a ésta (y a su empresa) para que se acreditase dicho extremo. La hoy demandada -que era administradora de la sociedad mercantil Libertas 7- negó la existencia de esas pólizas, y el árbitro en el laudo (párrafos 115 a 117) declara que no se ha probado su existencia (apartado V.3). El laudo trascribe las respuestas (que niegan la afirmación de contrario) obtenidas tras los requerimientos efectuados en las órdenes procesales tercera y sexta, y concluye (epígrafe 117) que ‘no ha quedado acreditada la existencia de otras pólizas…’. 2.- Si por derecho a la contradicción debemos entender la garantía de poder alegar y probar en un proceso el hecho que se afirma, no podemos concluir otra cosa que su incuestionable observancia por el árbitro. La compañía C. alegó un hecho, el árbitro dispuso cuanto estaba en su mano para verificar su certeza, la parte contraria lo negó de forma explícita y tajante, y en el laudo -a falta de otros elementos acreditativos- se da por no probado. La conclusión responde a la lógica más elemental que sirve de pauta al proceso civil, de plena aplicación a la dinámica del arbitraje en cuanto la carga de la prueba de los hechos que se afirman recae sobre la parte que sostiene la alegación. En este caso, la afirmación de la compañía aseguradora de que existían otras pólizas de cobertura de seguro de la responsabilidad civil distintas a la litigiosa se hizo huérfana de cualquier elemento acreditativo, y el resultado del requerimiento a la demandante arbitral llevado a cabo por el árbitro para que aportase estas hipotéticas pólizas obtuvo como resultado la negación de su existencia. No podrá negarse que se produjo contradicción efectiva; la hoy demandante de nulidad tuvo ocasión de alegar un hecho (que suponía en su simple afirmación); el árbitro -dentro de sus posibilidades y en directa correspondencia a la pertinencia de la prueba admitida- indagó el grado de veracidad que encerraba dicha alegación a través del único medio que tenía a su alcance (el requerimiento a través de orden procesal) (…).
El art. 24.1º CE, que regula el derecho a la tutela judicial efectiva, supone, positivamente, el acceso al proceso y al uso de los instrumentos que en él se proporcionan para la defensa de los propios intereses, con el límite más trascendente, formulado negativamente, de la prohibición de indefensión a que se alude en su inciso final, garantía que, en sentido amplio, implica el respeto del esencial principio de contradicción, de modo que los contendientes, en posición de igualdad, dispongan de las mismas oportunidades de alegar y probar cuanto estimaren conveniente con vistas al reconocimiento judicial de sus tesis’. Estas oportunidades fueron escrupulosamente respetadas en el procedimiento arbitral. Ahora bien: como sostiene la contestación a la demanda, lo que no garantiza el principio de contradicción es un concreto resultado; en este caso un resultado específico de prueba. De ahí que, si fracasa, la única construcción expositiva lógica a plasmar en la resolución, será que no ha resultado probado el hecho alegado. Esto es cuanto se afirma en el laudo cuestionado por la compañía aseguradora, y no se desmiente a través del despliegue de la actividad probatoria que incumbía a quien afirmaba la existencia de las pólizas. En la demanda se imputa a la parte asegurada una actitud ‘contumaz’ al negarse a entregar al árbitro otras pólizas, presentando esta actitud como una especie de desobediencia fraudulenta que, según el escrito por el que se impulsa esta acción, impidió conocer la realidad de la cobertura, y por lo tanto llevar a efecto un reparto del pago de la indemnización del siniestro. En el procedimiento arbitral, las facultades con las que cuenta el árbitro a la hora de practicar las pruebas admitidas no resultan totalmente equiparables en intensidad a las de un Juez, pues solo éste viene revestido de la potestad que le otorga su posición constitucional. Por ello, conceptos como el de ‘requerimiento’ o ‘incumplimiento’ -que laten en el argumento analizado- no pueden llevar a pensar que más allá de la clara y expresa petición de respuesta, el árbitro contase con instrumentos que pudiesen conminar a la destinataria del ‘requerimiento’ a presentar los documentos que la compañía aseguradora afirma que existían. La prueba se declaró pertinente, se llevó a la práctica dentro de las facultades que son propias del poder de dirección de un árbitro, y su resultado fue infructuoso desde el punto de vista de las pretensiones de la compañía. En suma: ésta no acreditó el hecho que afirmaba, pero no tuvo traba alguna en el intento de demostrar el extremo en que fundaba su pretensión y por ello, siendo ésta la cuestión nuclear en el análisis de la denuncia de falta de garantías, no podemos concluir sino apreciando que el motivo primero de la presente demanda adolece de una inconsistente invocación de la vulneración del orden público procesal, y no puede verse acogido”.
“(…) El siguiente motivo de impugnación se plantea también como un supuesto de vulneración del orden público procesal, al entender que el laudo descansa en una manifiesta arbitrariedad, que en el rótulo de este motivo se identifica con falta de motivación (pág. 16 de la demanda). 1.- Ante todo deberíamos indicar que no distingue la demanda con precisión entre lo que ha de entenderse por motivación arbitraria y lo que en puridad merece ser calificado como falta o ausencia de motivación. No son conceptos sinónimos. En cualquier caso, tratando de huir de la invitación a esta Sala para que entre en el análisis de las razones de fondo, lo que se cuestiona es el entendimiento que el árbitro tuvo de un concepto jurídico: el de suma asegurada. Se nos sitúa -por muchas cautelas que exprese la demanda- ante una labor que excede de la limitada verificación que nos compete. Pero además, se construye la demanda sobre una presentación de la litis que no se corresponde con la realidad. Se nos dice (párrafo 42) que el propio laudo reconoce que la suma asegurada estaba ya agotada, e inexplicablemente en el párrafo siguiente se hace alusión a los epígrafes 118 a 135 del laudo arbitral, que abordan el agotamiento de la suma y expresan lo contrario de lo que sostiene la demanda. 2.- Si se leen tales epígrafes se comprueba la importancia otorgada por el árbitro a esta cuestión, planteada claramente en el procedimiento cuya resolución llevó a cabo. Recoge el laudo (120) que el límite máximo de la Póliza litigiosa es de 6.000.000 euros; desglosa a continuación los sublímites existentes por conceptos (121); y seguidamente argumenta con detalle la importancia del carácter no concurrente de las coberturas de anticipo de gastos de defensa y de constitución de fianzas pecuniarias (124). Pero es que, en un desarrollo analítico que no admite reproche, el laudo expresa exactamente lo contrario de lo que la demanda nos traslada. El árbitro concluye, delimitando los diferentes conceptos comprendidos en la póliza, que la suma asegurada, en el momento de la reclamación, NO estaba agotada (epígrafes 126 y 129); acota cada concepto y concluye (135) con la desestimación de la tesis de C. Tras la lectura del laudo, no es posible advertir en modo alguno ausencia de motivación en torno a este argumento nuclear. El árbitro explica y razona por qué no considera que la suma asegurada estuviese agotada, y no se puede pretender (hemos de insistir en ello) que esta Sala lleve a cabo un enjuiciamiento paralelo del alcance en el supuesto concreto del contenido de los arts. 8.5º o 74 (in fine) de la Ley 50/1980, de 8 de octubre, del contrato de seguro. Ello implicaría traspasar los límites del correcto entendimiento de la acción de anulación, que no puede pretender la obtención de un análisis judicial del fondo del asunto, por mucho que las conclusiones a las que se hubiese llegado por un Tribunal fuesen distintas de las que culminan un laudo dictado en el escenario arbitral. 3.- Pero es más: en el presente supuesto, tampoco cabe encajar la exposición argumental llevada a cabo por el árbitro en el concepto de arbitrariedad. Englobamos en este concepto varias posibilidades. Hemos de entender por tal, ante todo, un ejercicio de voluntarismo valorativo y/o decisorio, que colisione con el evidente resultado de la prueba, siempre que esta colisión pueda ser calificada de patente, sin necesidad de esfuerzos interpretativos. También será arbitraria una resolución si se sustenta en una carencia de lógica argumental que equivalga a la pura incongruencia. Por el contrario, aquel discurso que, partiendo de premisas correctamente extraídas de la prueba, se construya sobre una argumentación congruente con las cuestiones suscitadas y coherente con la deducción lógica, no podrá tacharse de arbitrario, incluso aunque pudieran existir otras soluciones jurídicamente defendibles.
Por la intensa relación que guarda el concepto de arbitrariedad con el de motivación absurda, viene a colación la cita de cuanto tuvimos ocasión de señalar en nuestra STSJ Madrid 10 de septiembre de 2019: ‘una motivación absurda sería aquella que se basase en argumentos inaceptables por su extravagancia, contradicción o incoherencia, por muy revestida que apareciese de formalidades o estructura externas’. Ninguna de estas deficiencias podemos observar en el razonamiento del laudo que nos ocupa. Dado que el resto de las páginas que en la demanda integran este motivo de impugnación se dedican a la trascripción de citas jurisprudenciales de contenido global sobre la motivación de las resoluciones judiciales, poco podemos añadir para dar cumplida respuesta al motivo de impugnación: no puede apreciarse arbitrariedad alguna en el razonamiento del laudo ni en la conclusión alcanzada acerca del extremo debatido”.
“(…) El motivo tercero, titulado también al abrigo del orden público procesal, denuncia incongruencia extra petita del laudo, en cuanto se refiere a la condena que contiene por concepto de intereses moratorios (…). No es verdad cuanto se nos dice en la demanda de anulación: la demandante arbitral había solicitado de manera explícita y sin ambigüedades la adición a las cantidades principales reclamadas de los intereses moratorios, y por lo tanto, ninguna infracción del principio de congruencia puede apreciarse en la resolución que aclara, corrige y complementa (con motivación concreta y suficiente) lo expresado en el laudo principal. 2.- La posibilidad de complementar, aclarar o corregir un laudo mediante otra decisión adicional aparece contemplada con detalle en el art. 39 LA, en línea similar a la que para las resoluciones judiciales se contiene tanto en la LOPJ como en la LEC. La intangibilidad de las resoluciones -judiciales y también arbitrales- una vez firmadas no impide su corrección cuando se haya incurrido en patente error, olvido u oscuridad. Más que un recurso se trata, como ha destacado tradicionalmente la doctrina, de un ‘remedio’ que a la par que limitaciones cuenta con indudables ventajas puestas incluso de manifiesto por la jurisprudencia a fin de evitar la declaración de nulidad de sentencias. De acuerdo con la jurisprudencia constitucional, entre los distintos supuestos contemplados en la ley como modalidades de la aclaración (explicación, corrección o complemento) cabe introducir aquellas variaciones que ni supongan una alteración de la fundamentación jurídica ni una modificación sustancial del sentido del fallo, poniéndose de este modo de relieve el alcance limitado que resulta propio del mecanismo de la aclaración. Señalan -a título de ejemplo- las STC 231/1991, de 10 de diciembre; 142/1992, de 13 de octubre; 111/2000, de 5 de mayo; 140/2001, de 18 de junio- 329/2010; que el error material que es rectificable de este modo es el que puede deducirse sin necesidad de hipótesis o interpretaciones, por lo que cabe rectificar, sin vulnerar el derecho a la tutela judicial efectiva, los errores cuya corrección no implica un juicio valorativo, ni exige nuevas operaciones de calificación jurídica, ni nuevas o distintas apreciaciones de prueba, ni resuelve cuestiones discutibles u opinables, por limitarse a los casos excepcionales cuya detección no requiere pericia o razonamiento jurídico alguno. En suma: se trata de un cauce encaminado a remediar inexactitudes, errores u omisiones en puntos concretos que resulta necesario corregir sin estridencias, mutaciones de la decisión o ‘traiciones’ a la argumentación ya comprendida en la resolución de que se trate y, que aun pudiendo ser trascendentes para la debida configuración del proceso o su resultado, no suponen una alteración debida a causas distintas que a un error o a un olvido cuya reparación encuentre explicación lógica y patente a la vista de la confrontación entre las pretensiones oportunamente deducidas y resolución que es preciso aclarar o completar, así como de las actuaciones a las que se debe. 3.- Lo que en la demanda de anulación se denuncia como intolerable mutación de lo resuelto no es tal. Da cumplida y minuciosa respuesta a la cuestión la contestación a la demanda, resaltando la coherencia de lo finalmente resuelto (por la vía legal del complemento aclaratorio) con las pretensiones inicialmente formuladas. No podemos más que compartir esta lectura de lo sucedido, al comprobar que el árbitro, lejos de extralimitarse en su pronunciamiento complementario, cuanto vino a subsanar fue la falta de correspondencia de sus cómputos y afirmaciones con lo expresamente pedido, justifica su rectificación y la asume -dentro de una lógica difícilmente rebatible- como un error. El motivo ha de correr la misma suerte que los anteriores”.
“(…) En el último motivo ya se aborda la denuncia de vulneración de orden público material. Se sustenta la demanda en una tesis directa: el laudo (el árbitro por tanto) ignora aspectos esenciales e imperativos de la legislación aplicable. Ignora el principio legal del límite de la suma asegurada, configurador del contrato de seguro y expresamente recogido en el art. 27 de su Ley reguladora. Aunque sistemáticamente se presenta este motivo en ordinal separado del segundo (previamente analizado en el FJ Quinto), el contenido es el mismo, aunque en esta ocasión articulado como infracción del orden público material (cuando antes se tachó de contrario al orden público procesal). El paralelismo al construir esta prolongación de la demanda es incontestable con lo ya expuesto: se vuelve a repetir que el Laudo reconoce que se ha agotado sobradamente el límite total de la suma asegurada (a lo que ya dimos cumplida respuesta contraria). Tan sólo dos novedades resultan dignas de reseña: la claridad con la que se nos ofrece la discusión en torno a una cuestión estrictamente de fondo, y la tímida alusión contenida en el párrafo 67 al concepto de ‘orden público económico’, que en realidad no se ve correspondida con las citas jurisprudenciales que le siguen, referidas todas ellas al concepto material de orden público. En cualquier caso, tampoco cabe atribuir aquí esa singularidad que en ocasiones ha podido cobrar el orden público económico, cuando el debate conduciría a que esta Sala se adentrase en una argumentación puramente jurídica, revisora sobre el fondo y sustitutiva de las razones desgranadas por el árbitro que ya hemos dicho que no se corresponden con lo que se nos refiere en la demanda, y además no incurren en ninguna suerte de irracionalidad. No es preciso por lo tanto, reiterar cuanto hemos dicho en el FJ de referencia, y el motivo ha de ser -por congruencia- desestimado también (…). Por todo ello, la demanda ha de ser desestimada”.
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