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KAJIAN MENGENAI TUNTUTAN PERDATA (BURGERLIJKE VORDERING)

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KAJIAN MENGENAI TUNTUTAN PERDATA (BURGERLIJKE VORDERING)

Tuntutan Hak atau Tuntutan Perdata (Burgerlijke Vordering) adalah suatu tuntutan hak yang mengandung sengketa atau perselisihan yang penyelesaiannya diajukan ke Pengadilan untuk mendapatkan putusan, yang disebut  disebut GUGATAN (contentious jurisdiction). Surat Gugatan dapat dibuat oleh Penggugat Prinsipal sendiri (pihak materil) atau oleh Kuasa Hukum yang ditunjuk secara sah berdasarkan Surat Kuasa Khusus. Secara umum dapat dijelaskan bahwa Surat Kuasa (power of attorney) adalah surat atau akta  yang berisi pelimpahan wewenang/kuasa  dari seseorang atau sekelompok orang  atau badan usaha atau pejabat tertentu kepada seseorang atau atau pihak tertentu untuk mengurus hal – hal yang disebutkan dalam surat kuasa tersebut. Dengan pelimpahan wewenang/kuasa tersebut maka Penerima Kuasa  atau Kuasa Hukum/Penasehat Hukum  dapat bertindak mendampingi dan/atau mewakili untuk dan atas nama  pihak yang memberi wewenang/kuasa tersebut  dalam urusan – urusan  pribadi, bisnis, ataupun permasalahan  hukum (legal dispute). Secara prinsip “Kuasa” (lastgeving, mandate) diatur dalam ketentuan Pasal 1792 s/d Pasal 1819 Kitab Undang – Undang Hukum Perdata (KUHPerdata). Sedangkan pengertian dari “Kuasa” atau “Pemberian Kuasa” disebutkan secara eksplisit dalam Pasal 1792 KUHPerdata, yang berbunyi: “Pemberian kuasa ialah suatu persetujuan yang berisikan pemberian kekuasaan kepada orang lain yang menerimanya untuk melaksanakan sesuatu atas nama orang yang memberikan kuasa”.

GUGATAN dapat dibuat oleh Hakim atau Ketua Pengadilan pada waktu Penggugat datang menghadap ke Pengadilan Negeri yang lazim disebut dengan GUGATAN LISAN (Mondeling Vordering). Dengan demikian, dapat disimpulkan bahwa suatu gugatan dapat diajukan dengan 2 (dua) cara, yaitu:

  1. Secara tertulis, sebagaimana dimaksud dalam Pasal 118 ayat (1) HIR/Pasal 142 ayat (1) RBg, yang menyebutkan: “Gugatan-gugatan perdata dalam tingkat pertama yang menjadi wewenang pengadilan negeri dilakukan oleh penggugat atau oleh seseorang kuasanya yang diangkat menurut ketentuan-ketentuan dalam pasal 147, dengan suatu surat permohonan yang ditandatangani olehnya atau oleh kuasa tersebut dan disampaikan kepada ketua pengadilan negeri yang menguasai wilayah hukum tempat tinggal tegugat, atau jika tempat tinggalnya tidak diketahui di tempat tinggalnya yang sebenarnya”.
  1. Secara lisan, sebagaimana dimaksud dalam Pasal 120 HIR/Pasal 144 ayat (i) RBg, yang diajukan kepada Ketua Pengadilan Negeri setempat berdasarkan ketentuan Pasal 118 het Herzine Indonesisch Reglement (HIR)/142 Rechtreglement voor de Buiten gewesten (RBg). Akan tetapi, sekarang Gugatan Lisan sudah tidak lazim diterapkan dalam proses peradilan perdata, bahkan berdasarkan Yurisprudensi (Putusan Pengadilan yang telah mempunyai kekuatan hukum tetap, inkracht van gewijsde) Nomor 369 K/Sip/1973 Tanggal 4 Desember 1975, dinyatakan bahwa “orang yang menerima kuasa tidak diperbolehkan mengajukan gugatan secara lisan”.

Sebagai pedoman perlu dikemukakan landasan yuridis (juridical basis) dari Gugatan Lisan lainnya yaitu Pasal 120 HIR, yang menegaskan bahwa “bilamana penggugat buta huruf maka surat gugatannya yang dapat dimasukkannya dengan lisan kepada Ketua Pengadilan Negeri yang mencatat gugatan”.

Dalam het Herzine Indonesisch Reglement (HIR) atau Rechtreglement voor de Buiten gewesten (RBg) tidak diatur mengenai pencabutan gugatan, akan tetapi diatur dalam ketentuan BRv (Reglement op the Burgerlijke Rechtsvordering), dengan ketentuan:

  1. Apabila  perkaranya belum diperiksa atau Tergugat belum menyampaikan jawaban, maka diperbolehkan;
  2. Apabila dalam pemeriksaan perkara di persidangan Tergugat telah menyampaikan jawaban, maka pencabutan gugatan harus dengan persetujuan Tergugat.

Pada dasarnya (basically), karena setiap pokok tuntutan (petitum) itu menyangkut kepentingan Tergugat, maka pengurangan petitum termasuk pengurangan dasar gugatan diperbolehkan karena secara prinsip tidak merugikan kepentingan hukum (legal interest)  Tergugat. Juga pengurangan subyek hukum (pihak) diijinkan, misalnya: semula menggugat A, B, C, tetapi karena ternyata C tidak ikut menguasai obyek sengketa dan tidak ada kepentingan hukum, kemudian yang digugat hanya A dan B. Namun demikian, dalam hal gugatan diubah atau ditambah pada prinsipnya tidak diperbolehkan, tetapi ironisnya  dalam praktek (in practice) dan termaktub dalam berbagai yurisprudensi adakalanya hal demikian ternyata diperbolehkan  dengan pembatasan atau syarat – syarat tertentu.

Dalam praktek peradilan perdata, YURISPRUDENSI  telah merumuskan kaidah – kaidah hukum  (legal rules) yang berkaitan dengan “mengurangi”, “menambah” atau “merubah” gugatan, dengan berbagai pertimbangan sebagai berikut:

–       Putusan Mahkamah Agung Republik Indonesia No. 434 K/Sip/1970 Tanggal 11 Maret 1971, kaidah hukumnya berbunyi: “Perubahan gugatan dapat dikabulkan asalkan tidak melampaui batas – batas materi pokok yang dapat menimbulkan kerugian pada hak pembelaan para Tergugat”;

–       Putusan Mahkamah Agung Republik Indonesia No. 1043 K/Sip/1971 Tanggal 13 Desember 1974 dan Putusan Mahkamah Agung Republik Indonesia No. 823 K/Sip/1973 Tanggal 29 Januari 1976, yang pada pokoknya menyatakan bahwa diizinkan perubahan atau tambahan dari gugatan, asal tidak mengakibatkan perubahan posita dan Tergugat tidak dirugikan haknya untuk membela diri (hak pembelaan diri) atau pembuktian;

–       Putusan Mahkamah Agung Republik Indonesia No. 226 K/Sip/1973 Tanggal 17 Desember 1975, kaidah hukumnya berbunyi: “Perubahan gugatan Penggugat Terbanding pada persidangan 11 Pebruari 1969 adalah mengenai pokok gugatan, maka perubahan itu harus ditolak”;

–       Putusan Mahkamah Agung Republik Indonesia No. 1720 K/Sip/1978, kaidah hukumnya berbunyi: “Karena Tergugat asal II telah menyetujui pencabutan gugatan dan tidak bersedia menghadap ke sidang, maka dapat dipandang bahwa Tergugat tersebut telah melepaskan kepentingannya dalam perkara ini, sehingga pencoretan namanya sebagai Tergugat tidaklah bertentangan dengan hukum”;

Yahya Harahap berpendapat bahwa perubahan  gugatan harus diajukan, bukan dimohonkan kepada Majelis Hakim. Hal itu dapat dipahami dari maksud Pasal 127 Rv, yang menyatakan: “Penggugat berhak untuk mengubah atau mengurangi tuntutannya sampai saat perkara diputus tanpa boleh  mengubah atau menambah pokok gugatan”.[1]

Perubahan gugatan merupakan hak dari Penggugat. Perubahan gugatan menurut Pasal 127 Rv mencakup perubahan tuntutan (identitas, posita, dan/atau petitum) dan/atau pengurangan tuntutan (posita dan/atau petitum). Karena perubahan gugatan merupakan hak, maka prinsipnya Penggugat-lah yang mengajukan permohonan  perubahan gugugatan untuk selanjutnya dinilai oleh Hakim apakah beralasan hukum atau tidak.[2]

Mengacu pada pendapat Mahkamah Agung Republik Indonesia, maka hal – hal yang perlu diperhatikan dalam perubahan gugatan, sebagai berikut:

  1. Perubahan gugatan diperkenankan, apabila diajukan sebelum Tergugat mengajukan jawaban dan apabila sudah ada jawaban Tergugat, maka perubahan tersebut harus dengan persetujuan Tergugat (Pasal 127 Rv);
  2. Perubahan gugatan tersebut dapat dilakukan apabila tidak bertentangan dengan azas – azas hukum secara perdata, tidak merubah atau menyimpang dari kejadian materil (Pasal 127 Rv; asal tidak mengubah atau menambah petitum, pokok perkara, dasar dari gugatan);
  3. Perubahan gugatan dilarang:
  4. Apabila berdasarkan atas keadaan/fakta/peristiwa hukum yang sama dituntut hal yang lain (dimohon suatu pelaksanaan hal yang lain).
  5. Penggugat mengemukakan/mendalilkan keadaan fakta hukum yang baru dalam gugatan yang dirubah.[3]

Selain itu, menurut Mahkamah Agung Republik Indonesia, “Gugatan dapat dicabut secara sepihak apabila Tergugat belum memberikan jawaban tetapi jika Tergugat sudah memberikan jawaban maka pencabutan perkara harus mendapat persetujuan dari Tergugat (hal ini tidak diatur dalam HIR atau RBg, tetapi ada dalam Pasal 271, 272 Rv)”. [4]

[1] M. Natsir Asnawi, Hukum Acara Perdata, Teori, Praktik dan Permasalahannya di Peradilan Umum dan Peradilan Agama, Penerbit UII Press, Yogyakarta, Cetakan Kedua, Tahun 2017, hlm. 296.

[2] M. Natsir Asnawi, Ibid, hlm. 297.

[3] Mahkamah Agung RI, Pedoman Pelaksanaan Tugas dan Administrasi Pengadilan dalam Empat Lingkungan Peradilan, Buku II, Jakarta, Edisi 2007, Tahun 2009, hlm. 58.

[4] Mahkamah Agung RI, Ibid, hlm. 58.

 

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Penulis: Appe Hamonangan Hutauruk, SH., MH.

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About Author: Appe Hamonangan Hutauruk

Appe Hamonangan Hutauruk selaku Penulis tunggal pada Website: "Law Firm Appe Hamonangan Hutauruk & Associates" adalah seorang "Pegiat Penegakkan Hukum dan Hak Asasi Manusia" serta "Pemerhati Sosial Kemasyarakatan" yang berprofesi sebagai Advokat (Advocate), Konsultan Hukum (Legal Consultant) dan Dosen (lecturer) pada salah satu Universitas swasta di Jakarta, selain itu juga menduduki jabatan sebagai Ketua Umum pada Lembaga Swadaya Masyarakat (LSM) bernama "Komunitas Masyarakat Anti Korupsi dan Penggelapan Pajak (KOMAKOPEPA). youtube.com/c/BeritaHukumKebijakanPublik
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