Meritíssimo Juízo de Direito da Vara de Família Distrital de Município, Estado do Pará.
Nome do menor, menor impúbere, neste ato representado por sua genitora, Sra. nome do representante do menor, nacionalidade, estado civil, profissão, número do RG órgão emissor, número do CPF, residente e domiciliada à endereço completo com CEP e bairro, Cidade, Estado, endereço eletrônico: e-mail da representante, por intermédio de seu advogado e bastante procurador (procuração em anexo – 02 Procuração), André Leão Pereira Neto, brasileiro, solteiro, advogado, inscrito na OAB Seção Pará, sob o nº 22.405 e no CPF sob o nº 876.197.922-87, residente e domiciliado na cidade de Belém, com escritório na Avenida Roberto Camelier, nº 518/68, Apartamento 101, Bairro: Jurunas, Belém, Estado do Pará, CEP nº 66025-420, Telefone/WhatsApp/Telegram (91) 988353458 / Tim: (91) 983494689, endereço eletrônico: contato@andreleao.conclave.pro.br, perante Vossa Excelência, propor
AÇÃO DE ALIMENTOS CUMULADO COM LIMINAR DE ALIMENTOS PROVISÓRIOS
em face de nome completo do representado, nacionalidade, estado civil do representado, profissão do representado, número de registro geral do representado, número do CPF do representado, residente e domiciliado no endereço completo do representado com CEP e bairro, cidade, Estado, endereço eletrônico: e-mail do representado, com fulcro nos artigos 1.694, 1.695 e 1.698 da Lei Substantiva Civil (Lei n° 10.406/2002), e na própria Lei n° 5.478/68 e com os artigos 227 e 229 da Constituição Federal Brasileira, pelo que expõem e a seguir requerem:
PRELIMINAR DE JUSTIÇA GRATUITA
A Requerente postula desde logo a concessão dos benefícios da JUSTIÇA GRATUITA, na forma da Lei Federal nº 1.060/1950 e Súmula nº 06 do Egrégio Tribunal de Justiça do Estado do Pará – TJE, por não possuir recursos suficientes para pagar às custas judiciais do processo, sem prejuízo do próprio sustento e de sua família, uma vez que a renda da família provém do seu companheiro já quase não suportam todas as despesas relativas ao sustento familiar, aí incluído cartão de crédito, financiamentos, conta de energia, tarifa de água, condomínio, supermercado, plano de saúde, escola, dentre outros.
Nos termos da Lei Federal n° 1.060/50, a simples afirmação da parte no sentido de que não está em condições de pagar às custas do processo e os honorários de advogado, sem prejuízo do sustento próprio e da respectiva família, é suficiente para o deferimento da Justiça Gratuita, consoante o art. 4° do referido Diploma Legal, que dispõe:
Art. 4º A parte gozará dos benefícios da assistência judiciária, mediante simples afirmação, na própria petição inicial, de que não está em condições de pagar as custas do processo e os honorários de advogado, sem prejuízo próprio ou de sua família.
§ 1º. Presume-se pobre, até prova em contrário, quem afirmar essa condição nos termos desta lei, sob pena de pagamento até o décuplo das custas judiciais.
Trata-se de presunção legal juris tantum de hipossuficiência no sentido de não poder a parte arcar com ônus da tramitação do processo, no caso do feito se delongar e se fizer necessário a interposição de recursos e demais instrumentos processuais.
Nesse sentido, tem entendimento uníssono a jurisprudência da Corte Superior, a seguir transcrita:
Ementa: PROCESSUAL CIVIL. AGRAVO REGIMENTAL NO AGRAVO EM RECURSO ESPECIAL. BENEFÍCIO. JUSTIÇA GRATUITA. DECLARAÇÃO DE POBREZA. PRESUNÇÃO RELATIVA. REEXAME DE MATÉRIA FÁTICA. IMPOSSIBILIDADE. SÚMULA 7/STJ. AGRAVO NÃO PROVIDO. 1. Para fins de concessão do benefício da justiça gratuita em favor das pessoas naturais, basta “a simples afirmação de se tratar de pessoa necessitada, porque presumida, juris tantum, a condição de pobreza, nos termos do artigo 4º da Lei nº 1.060/50″ (EREsp 1.055.037/MG, Rel. Min. HAMILTON CARVALHIDO, Corte Especial, DJe 14/9/09). 2. No caso, após a análise das condições objetivas para o enquadramento da hipossuficiência processual, entendeu o Tribunal de origem pelo indeferimento do benefício ao agravante. Assim, rever tal entendimento encontraria óbice no verbete
sumular 7/STJ. 3. Agravo regimental não provido. (AgRg no AREsp 326.132/RJ, Rel. Ministro ARNALDO ESTEVES LIMA, PRIMEIRA TURMA, julgado em 25/06/2013, DJe 02/08/2013)
Nesse diapasão segue a Súmula nº 06 do TJE/PA (Res. 003/2012 – DJ. Nº 5014/2012, 24/04/2012):
Enunciado:Para a concessão dos benefícios da justiça gratuita basta uma simples afirmação da parte declarando não poder arcar com as custas processuais, tendo em vista a penalidade para a assertiva falsa está prevista na própria legislação que trata da matéria.
Ademais, é imperioso ressaltar que o Advogado da Requerente está atuando pro bono, ou seja, sem cobrar ou receber qualquer valor a título de honorários contratuais.
Nesse sentido, tem se manifestado majoritariamente a jurisprudência do Superior Tribunal de Justiça que abaixo se colaciona:
Ementa: PROCESSO CIVIL. ASSISTÊNCIA JUDICIÁRIA GRATUITA. ADVOGADO PARTICULAR.
CONTRATAÇÃO PELA PARTE. HONORÁRIOS ADVOCATÍCIOS AD EXITO. VERBA DEVIDA. DISPOSITIVOS LEGAIS ANALISADOS: ARTS. 1º, IV, 5º, XXXV E LXXIV, DA CF/88, 3º, V, 4º E 12 DA LEI Nº 1.060/50; E 22 DA LEI Nº 8.906/94. 1. Ação ajuizada em 16.10.2009. Recurso especial concluso ao gabinete da Relatora em 04.10.2013. 2. Recurso especial em que se discute se a assistência judiciária gratuita isenta o beneficiário do pagamento dos honorários advocatícios contratuais. 3. Nada impede a parte de obter os benefícios da assistência judiciária e ser representada por advogado particular que indique, hipótese em que, havendo a celebração de contrato com previsão de pagamento de honorários ad êxito, estes serão devidos, independentemente da sua situação econômica ser modificada pelo resultado final da ação, não se aplicando a isenção prevista no art. 3º, V, da Lei nº 1.060/50, presumindo-se que a esta renunciou. 4. Recurso especial provido. (REsp 1404556/RS, Rel. Ministra NANCY ANDRIGHI, TERCEIRA TURMA, julgado em 10/06/2014, DJe 01/08/2014)
Ante os fundamentos acima consignados, e considerando a ausência de rendimento mensal da Demandante, por ser estudante, resta cristalino que o pagamento das custas processuais consumiria quase toda a renda de seu companheiro, ocasionando o não adimplemento das despesas ordinárias da família.
Assim, pugna a Impetrante pelos benefícios da Justiça Gratuita, por ser medida de direito e justiça.
DOS FATOS
Conforme faz prova as certidões de nascimento em anexo, o Requerente é filho legítimo do Requerido, fruto da união da Representante dos menores, e do Requerido.
Ocorre que o Requerido sempre se descurou do seu dever de contribuir para o sustento de seu filho.
As necessidades de criança, na idade do autor são muitas e notórias englobando, entre outras, despesas com: alimentação, vestuário, moradia, educação, assistência médica e lazer, como bem informa a planilha de gastos (documento em anexo – 08 Cálculos das Despesas Mensais do Requerente).
O Requerido vive uma vida a qual condiz com um grande poderia econômico, auferindo boa renda mensal, embora a representante do menor não saiba declinar o seu montante total, como demonstram fotos da vida do Requerido (documento em anexo – 22 – 51 Registros Fotográficos e em Vídeo).
A Representante legal é estudante, sendo sustentada por seu atual companheiro, e vem enfrentando dificuldades em manter um padrão de vida de seu com a atual renda do companheiro.
A criação do Requerente não deve recair somente sobre a responsabilidade de sua genitora, que são muitas e notórias, como por exemplo, alimentação, vestuário, moradia, assistência médica, odontológica, educação, dentre outras.
O Requerido, mesmo após registrar a criança em seu nome, obrigou a mãe a realizar teste de DNA, como pode ser visto em arquivo em anexo (documento em anexo – 09 – 12 Investigação de Vínculo Genético feito a pedido do Requerido), mesmo tendo vivido sobre o mesmo lar da Representante do menor antes do nascimento da criança e por um curto período até o nascimento do Requerente. Entretanto, quando procurado pela Representante legal do Requerente, este se negou a prestar auxílio, não restando outra alternativa se não a propositura da presenta ação.
DO DIREITO
De acordo com o Código Civil:
Art. 1.694 – Podem os parentes, os cônjuges ou companheiros pedir uns aos outros os alimentos de que necessitem para viver de modo compatível com a sua condição social, inclusive para atender às necessidades de sua educação.
§1º Os alimentos devem ser fixados na proporção das necessidades do reclamante e dos recursos da pessoa obrigada.
Art. 1695 – São devidos os alimentos quando o parente, que os pretende, não tem bens, nem pode prover, pelo seu trabalho, à própria mantença, e o de quem se reclamam, pode fornecê-los, sem desfalque do necessário ao seu sustento.
Dispõe o art. 1.696 da Lei Substantiva Civil (Lei n° 10.406/2002):
Art. 1.696 – O direito de prestação de alimentos é recíproco entre pais e filhos, e extensivo a todos os ascendentes, recaindo a obrigação, nos mais próximos em grau, uns em falta de outros.
E também:
Art. 1.710. As prestações alimentícias, de qualquer natureza, serão atualizadas segundo índice oficial regularmente estabelecido.
O dever de auxílio alimentício do pai ao suplicante também encontra fundamentação no art. 22 da Lei 8069/90, in verbis:
Art. 22 – Aos pais incumbe o dever de sustento, guarda e educação dos filhos menores, cabendo-lhes ainda, no interesse destes, a obrigação de cumprir e fazer cumprir as determinações judiciais.
Posicionamentos brilhantes são os de Frank, citado pelo magistral doutrinador Washington de Barros Monteiro e o de Yussef Said Cahali, citado pelo também ilustre doutrinador Ricardo Rodrigues Gama, os quais vão a seguir, transcritos in verbis:
“Convocar um ser humano a existência é assumir o compromisso de ser a sua providência e de arredá-lo do sofrimento e das privações”.
“Incumbe a cada qual e a ambos conjuntamente, sustentar os filhos, provendo-lhes à subsistência material e moral, fornecendo-lhes alimentação, vestuário, abrigo, medicamentos, educação, enfim, tudo aquilo que se faça necessário à manutenção e sobrevivência dos mesmos”
Ressalta-se, ainda que, com a intenção de proteger os suplicantes, a Legislação instituiu o disposto no art. 4º da Lei 5.478/68, vindo dispor que, ao despachar o pedido, o juiz fixe desde logo alimentos provisórios, a serem pagos pelo Requerido, exceto no caso da Requerente vir a declarar que deles não necessita.
Art. 4 – Ao despachar o pedido, o juiz fixará desde logo alimentos provisórios a serem pagos pelo devedor, salvo se o credor expressamente declarar que deles não necessita.
§ Único. Se se tratar de alimentos provisórios pedidos pelo cônjuge, casado pelo regime de comunhão universal de bens, o juiz determinará igualmente que seja entregue ao credor, mensalmente, parte da renda líqüida dos bens comuns, administrados pelo devedor.
A Constituição Federal de 1988 assegura consagradamente os direitos da criança e do adolescente, in verbis:
Art. 227 – É dever da família, da sociedade e do Estado assegurar à criança e ao adolescente, com absoluta prioridade, o direito à vida, à saúde, à alimentação, à educação, ao lazer, à profissionalização, à cultura, à dignidade, ao respeito, à liberdade e à convivência familiar e comunitária, além de colocá-los a salvo de toda forma de negligência, discriminação, exploração, violência, crueldade e opressão.
Art. 229 – Os pais têm o dever de assistir, criar e educar os filhos menores, e os filhos maiores têm o dever de ajudar e amparar os pais na velhice, carência ou enfermidade.
Demonstrada a imperiosa necessidade dos alimentos por parte do suplicante, passa este a pedir.
DOS ALIMENTOS PROVISÓRIOS
Os alimentos provisórios pleiteados na presente ação têm como objetivo promover o sustento dos menores na pendência da lide. Encontra-se previsto no art. 4º da Lei 5.478/68, que dispõe sobre a ação de alimentos, senão vejamos:
Art. 4º. Ao despachar o pedido, o juiz fixará desde logo alimentos provisórios a serem pagos pelo devedor, salvo se o credor expressamente declarar que deles não necessita.
No caso sub examine, resta translúcido a necessidade de fixação de tal provisão legal, face à dificuldade financeira enfrentada pela genitora do menor, o que fatalmente resvala na manutenção da criança.
Isto posto, com o objetivo de propiciar ao Autor os meios à sua mantença digna, requerem-se os presentes alimentos provisórios, até o julgamento final da presente ação, quando então deverão ser os mesmos revertidos em definitivos.
DO PEDIDO
Ante o exposto, considerando que a pretensão do Requerente encontra arrimo nos artigos 1.694 a 1.710 do Código Civil e na Lei nº 5.478/68-LA, requer:
Primeiramente, o deferimento da justiça gratuita com fulcro na Lei 1.060/50, tendo em vista que a Representante legal do Requerente é pessoa pobre na acepção jurídica do termo, isentando-o de quaisquer custa processual;
Receber a presente inicial, uma vez demonstradas as condições da ação e os pressupostos processuais para, ao final, após o regular trâmite previsto em lei, JULGAR por sentença o presente pedido procedente em todos os seus termos, com o efetivo acolhimento do pedido alimentos ao Autor, no quantum e na forma aqui pleiteadas;
Fixar alimentos provisórios, até julgamento final da ação, quando então os alimentos serão convertidos em definitivos em favor do requerente, no valor não inferior a R$ 1733,62 (mil setecentos e trinta e três reais e sessenta e dois centavos) valor este das despesas mensais com a criança (documento em anexo – 08 Cálculos das Despesas Mensais do Requerente), acrescidos do repasse integral do abono família, incidindo ainda o percentual sob o 13º salário, férias, horas extras, rescisão contratual, seguro desemprego, afora os descontos obrigatórios de lei, caso o mesmo trabalhe com registro na CTPS.
Ou caso o Requerido trabalhe no mercado informal, que fique de logo registrado em sentença o dever de pagar o correspondente a R$ 1733,62 (mil setecentos e trinta e três reais e sessenta e dois centavos), reajustado anualmente de acordo com o índice oficial do governo, a ser pago mediante recibo ou mediante depósito, até o dia 10 (dez) de cada mês, em conta de depósito judicial, Favorecida nome da representante, conta da representante, Agência XX, Tipo de Conta XX , Número da Conta XX .
DETERMINAR a citação via ar de nome do representado, no endereço supra citado, para responder à presente ação, querendo, no prazo legal, sob pena de, em assim não procedendo, sofrer os efeitos da REVELIA, bem como, acompanhá-la em todos os seus termos, até decisão final, quando espera seja o feito julgado procedente, com a sua condenação a prestar alimentos definitivos ao autor;
Da mesma forma, CONDENAR o Promovido a suportar o ônus da sucumbência, com o pagamento das custas processuais e honorários advocatícios, na base de 20% (vinte por cento) do valor da causa, os quais deverão ser revertidos em favor de André Leão Pereira Neto, Banco XX, Conta: XX, Agência: XX, CPF: XX, tudo em conformidade com a Lei no 1.146/87.
INTIMAR pessoalmente o respeitável representante do Ministério Público Estadual, para participar em todo o processo.
Requer ainda, que as publicações sejam feitas em nome do advogado André Leão Pereira Neto, brasileiro, solteiro, advogado, inscrito na OAB Seção Pará, sob o nº 22.405 e no CPF sob o nº 876.197.922-87, residente e domiciliado na cidade de Belém, com escritório na Avenida Roberto Camelier, nº 518/68, Apartamento 101, Bairro: Jurunas, Belém, Estado do Pará, CEP nº 66025-420, Telefone/WhatsApp/Telegram (91) 988353458 / Tim: (91) 983494689, endereço eletrônico: contato@andreleao.conclave.pro.br.
Protestam provar o alegado por todos os meios de prova admitidos em direito, em especial pelo depoimento pessoal do Requerido, a juntada ulterior de documentos, oitiva de testemunhas, posteriormente arroladas, e o que mais se fizer necessário ao fiel deslinde da questão, ficando, desde logo, tudo requerido, bem como todas as diligências que se fizerem necessárias ao bom andamento processual.
Dá-se à causa o valor de R$ 20.803,44 (vinte mil oitocentos e três reais e quarenta e quatro centavos), ou seja, 12 (doze) prestações mensais de alimentos de acordo com o art. 292, III, do Código de Processo Civil.
Pede deferimento.
Icoaraci, Estado do Pará, 18 de fevereiro de 2018.
André Leão Pereira Neto
OAB/PA nº 22.405
Relação de Documentos:
· Procuração;
· Documentos Pessoais da Responsável pelo Requerente;
· Certidão de Nascimento do Requerente;
· Cálculos das Despesas Mensais do Requerente;
· Investigação de Vínculo Genético feito a pedido do Requerido, mesmo tendo registrado o Requerente em seu nome;
· Lista de material escolar;
· Matrícula escolar;
· Solicitação de Compra feita pela Responsável do Requerente, entretanto o Requerido comprou coisas fúteis
· Gastos com alimentação, lazer, brinquedos, móveis e supermercado;
· Registro Fotográfico provando que o pai da criança frequenta festas, mesmo alegando que não tem como pagar nada ao Requerente;
· Pai do Requerido demonstrando poder aquisitivo;
· Carro do Requerido;
· Lancha a qual pertence ao Requerido;
· Demonstrativo de que o Requerido tem poder aquisitivo para comprar um celular a qualquer momento;
· Conversa da mãe do Requerido se dispondo a ajudar o Requerente e demonstrando quanto o Requerido recebe por mês;
· Vídeos de festa com a Presença do Requerido.
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