Violência doméstica e Ação Incondicionada

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CEBRASPE (2021):

QUESTÃO CERTA: A autoridade policial instaurou inquérito policial em virtude de crime de lesões corporais leves cometidos contra mulher no âmbito familiar. O inquérito foi relatado e enviado ao Poder Judiciário. Considerando essa situação hipotética julgue o item seguinte. Por se tratar de ação pública incondicionada, é correto afirmar que a instauração do inquérito policial se deu independentemente de representação da vítima.

Gabarito: CERTO

Por ocasião do julgamento da ADF, o STF firmou a orientação de que a natureza da ação do crime de lesões corporais, praticadas no âmbito doméstico, é sempre a pública incondicionada, sem possibilidade de retratação da vítima, não importando em que extensão (leve, grave ou gravíssima, dolosa ou culposa). Com isso, o STJ reviu sua jurisprudência e passou a acompanhar o entendimento do STF sobre a matéria, publicando então a Súmula 542: “A ação penal relativa ao crime de lesão corporal resultante de violência doméstica contra a mulher é pública incondicionada”. Ou seja, independentemente de representação da vítima.

CEBRASDPE (2019):

QUESTÃO ERRADA: Considerando-se exclusivamente o entendimento sumulado do STJ, é correto afirmar que o juiz de direito substituto agirá corretamente se: Aceitar a retratação de vítima e extinguir o processo no caso de crime de lesão corporal resultante de violência doméstica contra mulher: essa ação penal é pública condicionada.

Incorreta. Súmula 542 do STJ: “A ação penal relativa ao crime de lesão corporal resultante de violência doméstica contra a mulher é pública incondicionada”.

CEBRASPE (2023):

QUESTÃO ERRADA: Nos casos de crimes de lesões corporais leves e culposas, a ação penal é condicionada à representação.

Súmula 542, STJ: A ação penal relativa ao crime de lesão corporal resultante de violência doméstica contra a mulher é pública incondicionada.

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A razão invocada pelo STJ para reconhecer que o crime de lesão corporal no âmbito da violência doméstica é de ação penal pública incondicionada se deu pelo seguinte fato: Até a edição da Lei 9.099/95 (lei dos juizados) o crime de lesão corporal era de ação penal pública incondicionada. A lei dos juizados inovou e, no seu art. 88, tornou os crimes de lesão corporal como de ação penal pública condicionados à representação. Art. 88. Além das hipóteses do Código Penal e da legislação especial, dependerá de representação a ação penal relativa aos crimes de lesões corporais leves e lesões culposas.

Como a Lei Marida da Penha estabeleceu que a lei 9.099/95 não se aplica aos crimes praticados com violência contra a mulher, essa mudança também não valeria para tais crimes, de modo que a lesão corporal no âmbito da violência doméstica e familiar contra a mulher continua a ser de ação penal pública incondicionada.

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