A la hora de presentar la solicitud de nacionalidad española por residencia son muchos los expedientes que suelen alargarse indefinidamente sin obtener una resolución por parte de la Administración, dejando en una situación de desamparo al extranjero. Ante esta situación ¿Qué puede hacer el extranjero? En el presente artículo te lo explicamos.
I. ¿Cuál es el plazo legalmente establecido para resolver las solicitudes de nacionalidad española?
El primer lugar empecemos por conocer cuál es el plazo máximo en el cual según la ley nuestro expediente ha de ser resuelto. El plazo máximo legalmente establecido que goza la Administración para resolver las solicitudes de nacionalidad española es de un año, y así lo establece el artículo 11.3 del Real decreto 1004/2015, de 6 de noviembre, por el que se aprueba el Reglamento por el que se regula el procedimiento para la adquisición de la nacionalidad española por residencia, el cual recoge lo siguiente:
Artículo 11. Propuesta y resolución
[…]
3. El procedimiento deberá ser resuelto y notificado en el plazo máximo de un año desde de que la solicitud haya tenido entrada en la Dirección General de los Registros y del Notariado. Transcurrido el plazo aludido sin que haya recaído resolución expresa, se entenderán desestimadas las solicitudes formuladas por los interesados.
La desestimación de la solicitud por la finalización del plazo sin ser resuelta la solicitud es lo que se conoce como silencio administrativo negativo. El silencio administrativo negativo lo podemos definir como la ausencia de manifestación expresa de la Administración pública y la atribución, a esa de actuación, de consecuencias desestimatorias en cuanto a lo solicitado.
No obstante, y aunque la ley exprese que transcurrido un año sin que el procedimiento sea resuelto se entiende el mismo como desestimado, hemos de aclarar que ello no significa que el interesado no tenga el derecho de adquirir la nacionalidad española y que por ello se le desestima su pretensión.
Lo que sucede en la práctica es una grave escasez de medios materiales y personales de la Dirección General de los Registros y del Notariado (Organismo encargado de elaborar la correspondiente propuesta de resolución de concesión o denegación de la solicitud de nacionalidad para su elevación al Ministro de Justicia), cuestión que les imposibilita el resolver de forma expedita la gran avalancha de solicitudes de nacionalidad española presentadas en los últimos años.
Por tanto, nos encontramos con un retraso importante en la resolución de solicitudes de nacionalidad española, habiendo gran cantidad expedientes desde el año 2015 (incluso anteriores) aún sin resolver. Según información proporcionada por el Ministerio de Justicia, a fecha de 31 de enero de 2020, el número total de expedientes de nacionalidad por residencia pendientes de resolver es de 291.000, y se han facilitado los siguientes datos:
- Los expedientes correspondientes al año 2016, ya han sido incorporados a la aplicación de gestión y tienen número “R” asignado. En los casos en los que no es posible la notificación electrónica, se estaban realizando notificaciones a los interesados de manera progresiva, tras la entrada en vigor del Convenio mencionado.
- Los expedientes correspondientes a los años 2017-2019 en formato papel y digital (pdf), se van incorporando a la aplicación y está previsto que este proceso acabe antes del verano de 2020. En aquellos casos en los que el interesado no disponga de número para efectuar su consulta en la aplicación denominada coloquialmente “cómo va lo mio” (web del Ministerio de Justicia en la que se consulta el estado de los expedientes de nacionalidad), recibirá notificación del número cuando el expediente esté incorporado a la aplicación.
- Los expedientes pendientes de resolución del año 2016, ascienden a un total de 60.377 y de 2017, a un total de 71.092.
- En el año 2018 se inició la tramitación y resolución de los expedientes que se presentaron a través de sede electrónica, precisamente porque, como se ha dicho, no necesitan tratamiento adicional al estar ya en la aplicación de gestión. En diciembre de 2019 se ha comenzado a tramitar y notificar los expedientes en los que no existía notificación electrónica expresa.
- Los expedientes sin resolver (a fecha 31.12.2019), correspondientes al año 2018 ascienden a un total de 56.192; los de 2019 a 64.210 y los de 2020 a 9.093.
- Los expedientes correspondientes a años anteriores que aún se encuentran pendientes de resolución, son 100 expedientes del año 2010; 134 del año 2011; 739 del año 2012; 1279 del año 2013; 4809 del año 2014, 23.055 del año 2015.
II. ¿Qué puedo hacer si ha pasado más de un año y mi solicitud de nacionalidad aún no ha sido resuelta?
En el caso que haya transcurrido un año desde que el ciudadano extranjero ha presentado su expediente de solicitud de nacionalidad española sin que el mismo haya sido resuelto el ciudadano extranjero tendrá dos opciones:
- La primera opción que se le presenta al extranjero será seguir esperando indefinidamente a la resolución del expediente. Como ya hemos explicado anteriormente, el hecho que la ley establezca el plazo máximo de un año para resolver el expediente de nacionalidad española, que el mismo no sea resuelto en dicho plazo no quiere decir que el extranjero no tenga derecho a la adquisición de la nacionalidad, lo que acontece, tal y como hemos explicado, es que hay un cúmulo de expedientes sin resolver de años anteriores. Por tanto, una vez pasado el año sin resolución de nuestra solicitud de nacionalidad española la misma se puede quedar sin resolver de forma indefinida dentro de esa gran masa de expedientes pendientes de resolución, por lo que el extranjero puede quedarse años esperando una respuesta de la Administración (Recordemos que hay expedientes pendientes de resolución hasta del año 2010).
- La segunda opción, y la más recomendada por nuestro despacho, será la de acudir a tu abogado de confianza con el objeto que el mismo interponga el respectivo recurso contencioso administrativo en contra de la desestimación presunta de nacionalidad española, cuestión que permitirá agilizar sustancialmente nuestra solicitud de nacionalidad española. En el siguiente punto explicamos con mayor detalle en que consiste el recurso contencioso administrativo por desestimación presunta de solicitud de nacionalidad española.
III. ¿Qué es el Recurso Contencioso-administrativo?
Podemos definir el recurso contencioso administrativo como aquél procedimiento judicial interpuesto frente a una disposición de carácter general o frente a un acto presunto o expreso llevado a cabo por cualquier organismo local, autonómico o central de la Administración Pública que sea promulgado con el objetivo de poner fin a la vía administrativa.
El mismo podrá utilizarse tanto contra la inactividad de la Administración Pública ante un requerimiento realizado por un interesado, tanto en contra de actuaciones materiales que vayan en contra de las leyes o que constituyan una vía de hecho.
En el caso concreto del Recurso Contencioso-administrativo en contra de las desestimaciones presentas de solicitud de nacionalidad española el órgano competente para resolver será la Audiencia Nacional.
Para la presentación del Recurso Contencioso-administrativo será obligatoria la asistencia de abogado (Colegiado) y procurador. El procurador es un licenciado en Derecho que representa a sus clientes antes los juzgados y los tribunales. Como representante es quien recibe las notificaciones del Juzgado referidas al procedimiento y quien presenta también los escritos.
Por tanto, la obligatoriedad de ser asistido por abogado y procurador, aunado a la presentación del recurso ante la Audiencia Nacional (Cabe recordar que la Audiencia Nacional es un tribunal de gran importancia, competente para resolver temas tan relevantes como: los delitos contra la corona o miembros del Gobierno, delitos de crimen organizado como terrorismo, narcotráfico, etc.), convierte el Recurso Contencioso-administrativo en un recurso no especialmente económico para el interesado.
Sin embargo, en relación con lo anterior, el interesado ha de evaluar que valora más, el tiempo que puede transcurrir a la espera de la resolución de su expediente, que como pudimos observar puede alargarse de manera indefinida, llegando a transcurrir hasta 10 años en el peor de los casos. O por otro lado, valora más la obtención de su nacionalidad española de la manera más rápida posible, y por ello está dispuesto a invertir en la consecución de la misma a través del Recurso Contencioso-administrativo.
A nuestro despacho son numerosos los clientes quienes han solicitado la agilización de sus respectivos expedientes de nacionalidad y quiene se han beneficiado de la interposición del respectivo Recurso Contencioso-administrativo. En un posterior artículo explicaremos en mayor detalle todo el procedimiento del recurso, si no te quieres perder de esa u otras noticias no olvides suscribirte a nuestro Newsletter.
Para más información escríbenos a info@, o llámanos al (+34) 666022794. Para no perderte ninguna novedad recuerda suscribirte a nuestro Newsletter , síguenos en Facebook y en Instagram y únete a nuestro canal exclusivo de Telegram.
Comm no o puedo contactarles???.solicite la nacionalidad en 2016 y aún está en “trámite”.
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Complements of her choices (style, hair), her interests, just pay attention to what she’s photographing and try to relate to it. People take pictures of their interests, mostly. So pretty much anything she’s taking a pic of is probably something she likes
Unless it’s a selfie, in which case, as I mentioned, complement something she chose, not something physical
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