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Eduvest –
Journal of Universal Studies Volume 3 Number 2, February, 2023 p- ISSN 2775-3735- e-ISSN 2775-3727 |
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EXECUTION OF THE OBJECT OF DEPENDENT RIGHTS THROUGH AUCTION BASED ON THE
PRINCIPLE OF PROPORTIONALITY |
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Tutiek Retnowati, Widyawati
Boediningsih, Muh. Gani Irwansyah Universitas Narotama
Surabaya, Indonesia cintashalawat@gmail.com |
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ABSTRACT |
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This
research was conducted to analyze the granting of credit by the Bank as the
creditor to the debtor with land as collateral to the bank if something goes
wrong with what was expected. If a credit problem occurs because the debtor
is incapacitated or because the debtor has failed in business which results
in reduced income so that obligations cannot be fulfilled, the Mortgage Law
(UUHT) exists to provide legal certainty for land rights including collateral
rights to land. Efforts made by the bank as a creditor if the debtor defaults
in order to obtain repayment due to bad credit, namely by executing one of
them through an auction. The research method uses normative research with a
statutory approach and a concept approach. This research resulted that the
execution of mortgage objects through auctions is still not in accordance
with the principles of proportionality and legal protection that can be given
to debtors, namely repressive and preventive legal protection. In its
development, the fact is that in the implementation of executions carried out
by creditors, the proceeds from selling mortgage objects through auction
execution are often below market prices and do not give the debtor the
opportunity to sell mortgage objects privately. Regarding this matter, Article 20 paragraph
(2) of the Mortgage Law (UUHT) has actually given a sufficient portion of
rights to the debtor for the sale of mortgage objects according to market
prices, but this is limited by the "on agreement" norm, which
actually hinders sales under the contract. |
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KEYWORDS |
mortgage
execution, auction, principle of proportionality |
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This work is licensed under a Creative Commons Attribution-ShareAlike 4.0 International |
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Land has a very
strategic function, both as a
natural resource and as a space for development, so that the need for
land will increase along with the development of development and an economy that requires land in the form
of land. With the increase in development and the importance of the role of
land, it will lead to a relationship between humans and land. To overcome difficulties in terms of capital in order to fulfill
obligations in the utilization and implementation of obligations to tano there
are several articles in the UUPA have been given flexibility to the holders
of land rights to acquire capital with land guarantees to banks. So based on several articles in the
UUPA in the implementation of obligations to land, Law Number 4 of 1996 concerning
Dependent Rights to Land and Objects related to Land
(hereinafter referred to as UUHT) (Cahyono,
2016).
UUHT was
formed to strengthen the realization of UUPA, namely by providing legal
certainty on land rights including land guarantee rights. In the case of providing
credit by the bank as a creditor to the debtor, namely credit (debt for the
benefit of the debtor) with land
guarantees to the bank, a relationship
arises The contract between
the creditor and the debtor is a credit agreement, where by
the parties want what is expected to be appropriate. But sometimes it turns
into what one of the parties to a
treaty does not expect. The cause of non-performing loans is because the debtor
is unable to or because the debtor has failed in
business which results in a decrease in income so
that it cannot be fulfilled obligations or indeed
the debtor in bad faith from the beginning by not wanting to pay (Desmawati
et al., 2020). Article 8 of Law Number 7 of
1992 Jo. Law Number 10 of 1998
concerning Banking (hereinafter referred to as the Banking Law) explains that
in terms of providing credit by banks, they must have
a which is pledged to the
bank and bound as a credit
guarantee. The binding of collateral with Dependent Rights is carried out if the debtor who
gets credit from the Bank, without
the debtor physically handing over the collateral to creditors indirectly make immovable
goods in the form of land (land rights) as a
debt guarantee. Physical collateral
goods remain the ownership of the debtor, but because
it is used as a debt guarantee with a Dependent Rights agreement, the authority of the Dependent Rights giver to carry out legal
actions with third parties resulting in a
decrease in the value of the guarantee limited to the Dependent Rights
owned by the Bank as the holder of the Dependent
Rights (Hadji
et al., 2012).
Land rights, both with the status of property
rights, building use rights, use rights, and business use rights are a form of
guarantee of land rights that are
often used as guarantee of dependent rights in bank credit agreements, because in general it has
a high price and is constantly
increasing. Generally, in banking practice, the value of credit guarantees is
greater than the amount of credit approved by the
Bank. To provide legal certainty as legal
protection, theencumbrance of this Dependent Rights
guarantee must be registered with the Land Office. The registration referred to
according to article 23 paragraph 2 of
the UUPA as a strong evidentiary tool
regarding the abolition of land
rights and the validity of the
transfer and encumbrance of these rights (Azam et al., 2017).
The efforts made by the bank as a creditor if
the debtor defaults to obtain repayment due to bad debts is by means of
execution through auction. Creditors can directly sell collateral items with
the help of the State Wealth and Auction
Service Office (hereinafter referred to as KPKNL) without having to ask for
permission (fiat) of the District Court. Article 6 of the UUHT states that if the debtor is injured, the Bank (creditor) as
the holder of the first dependent
right has the righ to sell the object of guarantee of the dependent right on its own power through a public
auction with the proceeds of the auction
as repayment of its receivables. Under article 20 paragraph 1 of the UUHT If it
is not promised the right, the creditor may request the District
Court to confiscate the execution of the collateral and sell the auction
through KPKNL, meaning that it must be
carried out through a public auction
because it is considered that in terms of public auction, the highest price
can be obtained against the object of
rights dependents (Priyono,
2018).
The fact that in the execution carried out by
creditors, the proceeds from the sale of dependent rights objects through
auction execution are often below the market
price. From the ruling there
is the same problem regarding the outcome. In the provisions of Article 20
paragraph (2) of the UUHT, it has
been stated that, "upon the agreement of the grantor and the holder of the
right of custody, the sale of the object of
dependent rights can be carried out under the hands of if
then it will be able to obtain a high price that benefits all
parties". The article has actually given a sufficient portion of the right
to the debtor for the sale of the object of dependent rights according to
the market price but it is limited by
the norm "ondeal" (Endratno, 2019).
Researchers
have also discussed
this issue, including "Legal
Protection for Banks Holding Second-Place Dependent Rights in Object Execution. Hak
Tanggungan" is a
journal written by Dimas Nur Arif Putra Suwandi at Universitas Airlangga
in the journal Media Iuris Vol. 1 No. 3,
October 2018, then a study entitled "Legal Protection for Parties
(Creditors And Debtors) Through Parate Executie Object of Dependent
Rights" is a journal written by Hirsanuddin
& Sudiarto at the University Mataram
in the journal IUS Journal of Law and Justice Studies Volume 9, Issue 1,
April 2021, then the research entitled "Legal Protection of Auction
Execution of Dependent Rights" is a
journal written by Asuan from the
Faculty of Law, University of Palembang
in the journal Solusi Vol 19, No, 2, May 2021 (Anungraeni, 2017).
Previous research when compared with research
conducted by the author, in this study
both discuss legal protection of parties in the execution of dependent rights objects However, what distinguishes
the research conducted by the author is the
previous research
limited to only in
the execution carried out by creditors, the proceeds from the sale of dependent rights objects through
auction execution are often below the market price, thus
the researcheran what the authors did was different from
previous studies. Meanwhile, in this study, the consideration of
the use of the proportionality principle is aimed at private banks and
commercial banks because both private and commercial banks are prone to
prosecution of the Financial Services Authority
(OJK) (Mahmud
Marzuki, 2010).
So it is hoped
that this research can be an enlightenment for parties interested in law enforcement and reference material in solving legal problems
RESEARCH
METHOD
The objectives to
be achieved in this study are to
analyze: first, the execution of the
object of dependent rights through auction in accordance with the
principle of proportionality, secondly, protection the law for debtors granting
dependent rights to auction the object of dependent rights below the market price
Normative legal
research, normative juridical research is a writing aimed at and
carried out by reviewing laws and
regulations and other written
legal materials that relating to this study.
Meanwhile, the research method used is normative juridical with a statue approach
and a Conseptual approach. The legal materials used in this study are primary
legal materials, secondary legal
materials, and tertiary legal materials. Primary legal materials are binding legal
materials in the form of laws and
regulations, as well as secondary legal
materials whose nature explains and supports primary legal materials between
Other related literature such as law books include law journals, theses, and
theses, as well as other libraries related to law.
RESULT
AND DISCUSSION
The principle of execution must be through public upfront sales or through
auctions, the rationale is that through an open auction sale, it is expected
that a price will be obtained reasonable or at least close to reasonable,
because in an auction a low bid can be expected to lure other bidders to try to
get the auction object by adding offer.
This is one of the manifestations for the protection of the law to the
guarantee.
Article 6 of the UUHT provides that if the debtor is injured, the holder of
the first dependent right has the right to sell the object of dependent rights
on his own power through public auction and take repayment of his receivables
from the proceeds of the auction. The
existence of auctions as public and private functions is urgently needed, and
the KPKNL is given very broad authority in carrying out including auction
execution by the Minister of Finance Regulation Number 27 / PMK.06 / 2016
concerning instructions for the implementation of the auction. Because by
selling through auctions, it is expected to reach the highest price.
In the implementation of auctions, especially auction execution of article
6 dependent rights, the potential for lawsuit is very high. The total number of
lawsuits in 2013 based on the State Wealth Media Bulletin Edition No.14
Year IV/2013, the lawsuits that went to
the DGT/KPKNL were 2,458 and as many as 1,500 more were g ugatan from auction
execution of article 6 dependent rights (Resti, 2022). The lawsuit was filed during the
pre-auction, conducted with the aim
of delaying the implementation of the auction and
post-auction, various motives behind it. There are several characteristics of
an unlawful perbuatan lawsuit in an auction.
But the reality in practice is
sometimes not as imagined as well as expected. J Satrio
mentions that, it seems that nowadays there is a reluctance of people to take
part in auctions, to be an executor in an execution, or at least People are
only interested in participating if there is hope of obtaining auction items at
low prices (Satrio,
2018). Likewise,
the costs that must be incurred for the implementation of the auction are not
cheap and to avoid any lawsuits arising from the implementation of the auction,
the dependent rights law facilitating
debtors with the existence of article 20 of the UUHT.
In this regard, lawmakers have realized, by
looking at certain events there is a
possibility of obtaining a better
price, if the sale is made in under hand
and therefore in article 20 paragraph (2) of the UUHT provides an
opportunity for execution to deviate
from the principle described above.
Article 20 paragraph (2) of the
UUHT provides an opportunity for the implementation of executions under the
hands, in the article it can be seen that there is protection of interests for
para party. The assessment of
collateral, which is carried out by the creditor, is estimated to be a
price smaller than the estimated
current selling price
and the estimated
selling price is smaller than
the creditor's credit, then the creditor
the holder of the dependent right
has a vested interest in the sale of the collateral object at a high price in the hope that the entire bill will be covered while the
dependent entitler also expects the price
which is high, because the rest of
the sale after being taken by the creditor is the right of the debtor as the grantor of dependent rights.
However, if the estimated sales price is far above the total creditor's bill,
then the creditor does not care whether the execution will be carried out
through auction or underhand sales. Because through any means it is estimated
that the bill can be repaid with the proceeds of the sale of collateral
objects.
The debtor as the grantor of dependent rights will think that the pledged
object will give a high sales result, because the debtor expects the remaining
money from the sale after deducting it to repayment of loan bills to creditors.
To maintain the possibility of misuse of the opportunity to sell objects under
the hands, several conditions are determined.
The sale of objects under the hands by the debtor can be carried out if it
meets article 20 paragraph (3) of the UUHT which states that:
"The
implementation of the sale as per paragraph (2) can only be carried out after
the lapse of 1 (one) month from the time it is notified in writing by the giver
and/or holder of the dependent right to interested parties and announced at
least in 2 (two) newspapers circulating in the area concerned and / or local
mass media and none of the parties expressed reservations"
In practice, what attracts attention is the existence of an obligation to
carry out sales under the hands but provided that there is an agreement between
the giver and the holder of the dependent rights, when viewed in article 20
paragraph (3) of the UUHT that to make an underhand sale takes a very long time
so that the provision "by agreement..." the creditor will certainly say that he does
not agree to make an underhand sale given the condition in article 20 paragraph
(3) of the UUHT, the creditor considers the sale under the hand slowing down
the time of repayment of debts secured by the object of dependent rights.
In this case, the bank as the creditor carries out the execution of the
dependent right object through auction, because the creditor considers that the
execution of the dependent right object by means of sale under hands slow down
the repayment time. But on the lain side in the implementation of the auction,
as explained above that many debtors file lawsuits with cases of auction sales
proceeds below the price market/fair price.
The execution of the dependent right object carried out through auction
where the debtor does not fulfill his obligations or defaults with the
guarantee of the dependent right object
in the form of land and is a guarantee
credit with a high economic value, is a priority over the guarantee of other
objects, then with the consideration of the object of dependent rights belongs to the
debtor, to The principles of
propriety, good faith, and respect for the property of others are of a very important
nature to creditors. But in practice it
is counterproductive because the bank as
the creditor nilaterally
determines the auction limit value of the dependent right
object, until the auction selling price
becomes very unnatural and well below the market price with the potential for auction
engineering by the auction mafia
which has become an open secret (Widhianingtanti et al.,
2019), this has become the
factor of a lawsuit from the debtor
because the debtor feels
aggrieved by not being given the right to participate in the determination of the auction selling price and feels in Lose with the proceeds of auction sales that are far below
the market price.
The object of dependent hak guaranteed by the
debtor tends to be safe because the object is pledged to the bank as the holder
of dependent rights and will not be destroyed unless a natural disaster occurs.
On redit loans provided by banks as creditors, in
addition to providing obligations to pledge land and/or buildings, creditors
also provide obligations to debtors to Repayment of loans with interes payable of 8.46% in 2022 initially on working
capital loans, 8.18% of investment loans, and 10.24% of consumption credit loans
which commercial banks give to creditors. The amount of interest rate that must
be paid by the debtor is calculated to be very large, so it can be seen that
the fairness of both parties is not proportion.
So the amount of interest rates and guarantees
of land and/or buildings pledged by the debtor must be balanced in order to achieve a sense of justice in
accordance with the proportions the
parties.
The proportional principle in a contract is defined as the principle
underlying the exchange of rights and obligations of the parties according to
their proportions or parts. This
proportionality of the division of rights and obligations that is embodied in
the entire process of contractual relations, whether in the precontractual
phase, the formation of contracts or the
execution of contracts, the principle
of PRoporsional
does not dispute the balance (similarity
of outcomes), but rather emphasizes the proportion of the division of rights
and obligations between the parties. The right of dependents as collateral is
part of the principal bond which is subject to the principle of proportionality
but, in the nature of the UUHT the principle of proportionality is reduced to
the existing norm in article 20 paragraph (2) of the UUHT which has been
mentioned above. With the elimination of the norm on the agreement in the UUHT,
and regulated the creditor gives a period of time to the debtor for approximately
3 (three) to 4 (four) months for underhand sales, and with underhand sales of
course still involving creditors because the object of dependent rights is on creditors as
dependent rights holders. And apabila debtor succeeds
by selling the object of dependent rights under the hand at a price that is
considered high and sufficient for the repayment of the debt to the creditor,
the certificate of land and/or building pledged by the debtor shall be given to
the purchaser of the sale under the hand as well as the grant of roya by the bank as abolition of dependent rights. That way at least a sense of justice arises that
corresponds to the proportion of rights and obligations of both parties.
LEGAL PROTECTION FOR DEBTORS WHO GIVE TANGGUNGAN RIGHTS TO AUCTION
DEPENDENT RIGHTS OBJECTS BELOW THE MARKET PRICE
The UUHT says public auctions are
expected to get high prices, as opposed to the many lawsuits filed by debtors
in court regarding the proceeds of auction sales that are far below the market
price is even far below NJOP. The
granting of an opportunity for the sale of the object of dependent rights under
the hands is limited by the norm "by agreement" so that the sale
under the hands cannot be carried out without the consent of the creditor. Finally the execution of the object of dependent rights is
mostly carried out through public auctions which in fact is not in accordance
with what is stated in the UUHT that publicauctions
can obtain a price high.
According to Satjipto Raharjo
Perlin, the law is to provide protection to the human rights of those harmed by
others and that protection is given to the community so that they can enjoy all rights granted by
law (Soekanto,
2016).
If you look at the legal protection of Philipus
M. Hadjon, legal protection is divided into two,
namely preventive legal protection and repressive legal protection is
associated with the legal protection of debtors, hence preventive legal protection
a The RTINYA of legal provisions can be presented as an effort to prevent
acts of
violation of the law. This effort is implemented by forming between laws
that are normative. Nothing can be pursued in preventive legal protection for
debtors in the event that the auction price is below the market price (Shamsul
et al., 2014).
Legal remedies that can be made
during the auction, namely by filing a lawsuit with the State Administrative
Court, if the KPKNL in the pre-auction stage agrees that a until auction will be held Until the
determination of the auction schedule
while the object of the auction is still in dispute. In the case of a limit
value that is too low below the market price, the ministerof
Finance Regulation No. 27/ PMK.06 / 2016 concerning instructions for the
implementation of auctions does not specifically regulate the submission
procedure cancellation of the auction after the auction is held. Article 31 of
the Minister of Finance Regulation No. 27 / PMK.06 / 2016 concerning
instructions for the implementation of auctions states that the cancellation of
auctions can only be carried out by lelang officials
if in the case of:
a.
Force majeur or force
majeure
b.
There are technical
problems that cannot be addressed at the auction without the presence of
auction participants
So that with auction procedures that have fulfilled the procedure, the
implementation of the auction isconsidered valid so
that for the problem of determining the limit value that is too low or far
below the market price only can be done through subsequent legal remedies,
resolved with repressive legal protection.
Repressive legal protection aims to
resolve the occurrence of disputes, which directs the government's actions to
be cautious. Repressive legal protection aims to resolve disputes, including
their handling in institutions. Repressive legal protection if it is associated
with the implementation of auctions, then repressive legal protection to
debtors has been regulated in laws and regulations. Because auctions are civil
trades in general, it can be used as a first legal remedy, namely through a
lawsuit to the District Court.
Lawsuit remedies that can be filed in the District Court on the basis of
article 17 paragraph (1), paragraph (2) and paragraph (3) of the
Minister of Finance Regulation No. 27 /
PMK.06 / 2016 concerning instructions for
auction implementation which regulates, that the seller is responsible for the validity
of ownership of the goods, the validity
of the auction requirements documents, the delivery of movable and/or immovable
goods, submission of ownership documents to the buyer and the last one can be used as the basis for the lawsuit, namely the setting of
a limit.
The regulations for the implementation of auctions and UUHT have not
provided for rights and obligations that are in accordance with the
proportions. The laws and regulations should provide justice to the debtor not
only to one of the parties in this case is the creditor, because in the
implementation of the auction the debtor also have rights that must be granted
in accordance with the proportion of obligations that the debtor has carried
out.
If the judgment of the court of
first instance is found to be an inappropriate judgment, then the next legal
remedy is as in the legal remedy in the civil procedural law, namely with
appeals and appeals. Legal remedies are the rights of the defendant that can be
exercised if the defendant is dissatisfied with the judgment rendered by the
court (Nurhayani,
2015). Such
remedy is an attempt given by law to a person or legal entity in a particular
case to resist the judge's decision as a place for parties who dissatisfied
with the judge's decision with what is desired and does not meet the sense of
justice, because the judge is also a human being who can make mistakes so wrong decide or side with the wrong party.
The main objective in court proceedings is to obtain a judge's ruling of
permanent legal force. However, any judgment handed down by a judge may not
necessarily guarantee juridical truth, because the decision cannot be separated
from errors and oversights, not even impossible to be impartial (Rafiq et al., 2017).
In order for those errors and oversights to be corrected, it is possible
to re-examine the judge's decision in an appropriate manner. To be able to
realize truth and justice is to carry out legal remedies.
Remedies against the judgment of the
first instance of the district court may file an appellate remedy which will be
examined and dealt with by the High Court, furthermore if there is still an
objection then the petitioner may appealn appeals to
be examined by Judges of the Supreme Court. If there are still objections, it
is possible to conduct a review which is the last resort and the final result
of the examination of the case on review can be said to be as the inkracht verdict.
This remedy is a right, where the right can be used and can also not be
used. If the right to apply for such remedies is exercised by the defendant,
the court shall accept it.
CONCLUSION
Based on the above explanation, the author draws conclusions, namely:
First, the execution
of the object of dependent rights is not in accordance with the principle of
proportionality, because in the UUHT there are several kinds of executions that
can be carried out but always end with the execution carried out objek dependent rights through auction with the
facilitation of underhand sales by the UUHT it is hoped that the rights that
the parties get are proportional, but the principle of
proportion is reduced by being limited to the norms that the parties get. requires an agreement with the
creditor. So that the execution of dependent rights through the sale of the
object of dependent rights under the hands is not guaranteed directly by law.
Secondly, That way
the legal protection that can be afforded to the debtor who gives the dependent
right to the auction of the object of dependent rights below the market price
is a repressive legal protection. Repressive legal protection that can be done
is by the first legal remedy, namely filing a lawsuit with the District Court and a lawsuit can be filed
with the State Administrative Court in the case of the implementation of the auction but the auction object is still in dispute
and the KPKNL agrees with the auction
of the object, if it is felt that the
judgment in the first instance is
obtained What is not appropriate, then the
next legal remedy is a legal remedy in the civil procedural law,
namely by appeal and cassation. And the last remedy is to apply for
judicial review
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