PROPIEDAD HORIZONTAL
Se declara haber lugar al recurso de casación interpuesto por Comunidad de Propietarios contra Sentencia desestimatoria de la Audiencia Provincial de Alicante, sobre solicitud de declaración como elemento común de una parte del subsuelo de la finca.
Los hechos debatidos se resumen en que bajo los locales comerciales de la finca existía una zona de aproximadamente 500 metros cuadrados, que no figuraba recogida en el título constitutivo de la propiedad horizontal y que no tenía reflejo registral alguno; indicaba que, pese a que la propietaria de los locales no ostentaba, ni tenía atribuido sobre tal espacio derecho alguno de uso exclusivo y excluyente, había procedido a horadar el forjado que separaba sus locales del espacio existente en el subsuelo que la actora consideraba común, para utilizar de modo exclusivo el mismo.
Ante ello la Comunidad reclamaba que se declarase que el espacio existente en la planta sótano, bajo los locales comerciales es un elemento común del edificio que pertenece en copropiedad a todos los propietarios de la finca para su uso y disfrute y que se condenara a la demandada a reponer el espacio comunitario en el estado en el que se encontraba antes de las obras de modificación realizadas.
El juzgado acogió la demanda y señaló que la demandada carecía de título sobre el sótano. Por el contrario la Audiencia Provincial en apelación indicó que los huecos que ahora configuran el sótano se dejaron sin hormigonar para que, tras la inspección municipal, se pudiera acceder por el propietario de los locales a esa zona; y valoró que el promotor de la obra atribuyó físicamente el espacio litigioso al propietario de los locales, aunque por los inconvenientes urbanísticos existentes, no se reflejara tal atribución en el Registro.
El TS revoca la sentencia de la Audiencia y ratifica el fallo del Juzgado reiterando la doctrina jurisprudencial de que el subsuelo de una comunidad de propietarios, cuando no tenga atribuida naturaleza privativa en el título constitutivo de la propiedad horizontal, ni exista una causa válida que justifique su atribución a un copropietario, tiene naturaleza de elemento común.
Fuente: Portal Difusión Jurídica
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