L’ASSICURAZIONE DI AUTOMEZZI NELL’AFFITTO DI RAMO D’AZIENDA
La disciplina sull’affitto di ramo d’azienda richiama in buona parte le norme sulla cessione d’azienda.
In particolare, ai fini del quesito in oggetto, è opportuno partire dall’art. 2558 c.c., rubricato “Successione nei contratti”, il quale stabilisce che “Se non è pattuito diversamente, l’acquirente dell’azienda subentra nei contratti stipulati per l’esercizio dell’azienda stessa che non abbiano carattere personale. […] Le stesse disposizioni si applicano anche nei confronti dell’usufruttuario e dell’affittuario per la durata dell’usufrutto e dell’affitto”.
La norma prevede, infatti, in modo chiaro che la successione automatica del cessionario di azienda riguarda tutti i contratti stipulati dal cedente per l’esercizio della stessa, ad eccezione di quelli aventi carattere personale e di quelli rispetto ai quali le parti abbiano espressamente escluso che si verifichi l’effetto successorio (Cass. Civ., 28 Marzo 2007, n. 7652).
Nel caso in oggetto, nel contratto di affitto di ramo d’azienda, le parti hanno pattuito espressamente che tra i beni oggetto del contratto vi sia anche l’autovettura aziendale.
In merito alla questione, più specifica, del contratto di assicurazione dell’autovettura, è necessario richiamare la giurisprudenza sul trasferimento d’azienda; tale giurisprudenza ha affermato che “nel caso di trasferimento dell’azienda, salvo patto contrario, unitamente ai beni cha la costituiscono si trasferiscono i contratti a prestazioni corrispettive non ancora completamente eseguite che non abbiano carattere personale, stipulati per l’esercizio di essa. […] La regola del trasferimento “ex lege” si applica, oltre che ai contratti di azienda, […] ai cosidetti contratti d’impresa che, per non avendo come oggetto diretti beni aziendali, sono attinenti all’organizzazione dell’impresa, come il contratto di assicurazione contro i danni. Conseguentemente, in caso di trasferimento dell’azienda si trasferisce pure il contratto di assicurazione contro danni che sia stato stipulato per l’esercizio di essa” (Cass. Civ., 7 Dicembre 2005, n. 27011). Secondo tale interpretazione giurisprudenziale, l’acquirente subentra nella posizione dell’assicurato in quanto nell’art. 2558 c.c. “l’interesse alla protrazione dei rapporti giuridici interenti all’esercizio dell’azienda, trova fondamento in una concezione unitaria dell’azienda che individua nei contratti altrettanti elementi della stessa” (Cass. Civ., 7 Dicembre 2005, n. 27011).
Stessa interpretazione è stata data dalla giurisprudenza in merito ai “contratti di impresa” (non aventi ad oggetto diretto beni aziendali, ma comunque attinenti all’organizzazione dell’impresa, come i contratti di somministrazione e di assicurazione), secondo la quale “nel caso di trasferimento di azienda, il contratto di assicurazione contro i danni, che sia stato stipulato dal venditore in relazione ai rischi inerenti all’esercizio aziendale,[…] resta soggetto alla disciplina dettata dall’art. 2558 c.c. in tema di successione dell’acquirente nei contratti stipulati dall’alienante” (Cass. Civ., 29 Gennaio 2003, n. 1278).
Si può, pertanto, ritenere che il richiamo espresso dall’art. 2558 comma 2 c.c. all’affitto di azienda, consenta di estendere l’interpretazione giurisprudenziale sulla successione nei contratti nel caso di cessione di azienda, anche alla successione dei contratti nel caso di affitto di azienda.
Sulla base di quanto esposto e sulla base dell’interpretazione giurisprudenziale sul trasferimento d’azienda, si ritiene che il contratto di assicurazione dell’autovettura aziendale, rientrante nel complesso dei beni oggetto dell’affitto di ramo d’azienda, debba trasferirsi all’affittuario, il quale avrà l’onere di saldare il premio d’assicurazione della stessa.
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