IL RAPPRESENTANTE DEI SINGOLI EDIFICI NEL SUPERCONDOMINIO

173

L’articolo 67 delle disposizioni per l’attuazione del codice civile prevede che, nel supercondominio, in alcune specifiche ipotesi ogni condominio è tenuto obbligatoriamente a designare un rappresentante di palazzina, al quale affidare la propria rappresentanza per la gestione ordinaria delle parti comuni ai diversi condominii e per la nomina dell’amministratore.
In particolare, tale obbligo scatta nel caso in cui i partecipanti siano, complessivamente, più di sessanta. Al di sotto di tale soglia, la nomina del rappresentante di palazzina non è obbligatoria ma può comunque essere fatta.
Si precisa che, ai fini del computo dei sessanta partecipanti, i comproprietari sono considerati come un solo condomino.
La nomina del rappresentante di palazzina va fatta dal SINGOLO condominio con il voto favorevole di un numero di voti che rappresenti la maggioranza degli intervenuti e almeno i due terzi del valore dell’edificio.

Se l’assemblea non vi provvede ma la nomina è obbligatoria, ciascuno dei rappresentanti già nominati può ricorrere all’autorità giudiziaria, previa diffida a rimediare entro un termine “congruo”.
La scelta del rappresentante non deve ricadere necessariamente su un condomino, ben potendo essere designato un soggetto esterno al condominio.
Il codice non ha specificato nulla sulla durata dell’incarico, sulla sua retribuzione, sulla revoca e sulla conferma, con ciò determinando una pericolosa lacuna legislativa.
Sebbene non manchino interpretazioni di segno opposto, deve ritenersi che la sua nomina non debba essere circoscritta a una sola assemblea né sottoposta a limiti di tempo: per una più snella e agile gestione del supercondominio, il rappresentante resta tale fino a che non venga sostituito.
Resta comunque possibile la revoca in ogni tempo, senza la necessità che si verifichino particolari condizioni.
L’unica limitazione soggettiva , desumibile dalla ratio della norma è questa : non può essere rappresentante l’amministratore. A dirlo è lo stesso art. 67 disp.att.c.c., laddove afferma che “All’amministratore non possono essere conferite deleghe per la partecipazione a qualunque assemblea”.
Il rappresentante “di palazzina” ha pieni poteri, in quanto l’articolo 67 delle disposizioni per l’attuazione del codice civile stabilisce espressamente che “Ogni limite o condizione al potere di rappresentanza si considera non apposto”.
In ogni caso, egli deve comunicare l’ordine del giorno e le decisioni assunte dall’assemblea dei rappresentanti dei condominii all’amministratore di condominio, il quale ne riferisce in assemblea, e risponde con le regole del mandato.
Circa i poteri dei rappresentanti di palazzina nel supercondominio, un particolare ruolo chiarificatore è stato assunto da alcune pronunce giurisprudenziali, che hanno chiarito che la delibera con la quale i rappresentanti revochino l’amministratore di supercondominio deve ritenersi affetta da radicale nullità (Tribunale di Milano n. 9844/2016).
Del resto, si tratta di una materia estranea alle attribuzioni istituzionali del rappresentante, che la legge limita espressamente alla gestione ordinaria delle parti comuni e alla nomina dell’amministratore, senza che sia possibile un’applicazione analogica (Corte d’appello di Milano n. 2321/2018).
Sono inoltre importanti alcune precisazioni stabilite dal codice :
Sulla nomina :
1 – Qualora alcuni dei condominii interessati non abbiano nominato il proprio rappresentante, l’autorità giudiziaria provvede alla nomina su ricorso anche di uno solo dei rappresentanti già nominati, previa diffida a provvedervi entro un congruo termine. La diffida ed il ricorso all’autorità giudiziaria sono notificati al condominio cui si riferiscono in persona dell’amministratore o, in mancanza, a tutti i condomini.
Il procedimento applicabile è quello tipico della volontaria giurisdizione.
2 – Ogni limite o condizione al potere di rappresentanza si considera non apposto. Il rappresentante risponde con le regole del mandato e comunica tempestivamente all’amministratore di ciascun condominio l’ordine del giorno e le decisioni assunte dall’assemblea dei rappresentanti dei condominii. L’amministratore riferisce in assemblea.

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