Covid- 19 : Quel sort pour le paiement des loyers découlant du bail commercial d’un local fermé ?
A l’instar de plusieurs pays, le Maroc connaît, depuis plusieurs semaines, une crise sanitaire exceptionnelle, méconnue jusqu’alors, liée à l’épidémie Covid-19.
Pour faire face à cette crise sanitaire, les autorités marocaines ont adopté des textes juridiques qui réglementent cette situation inédite. Ainsi, il a été publié au Bulletin Officiel du 24 mars 2020, le décret-loi n°2-20292 du 23 mars 2020 portant sur les dispositions relatives à l’état d’urgence sanitaire et aux procédures de sa déclaration, lequel texte pose le cadre général de l’état d’urgence sanitaire.
Notons que ce décret-loi a été approuvé par le Dahir 1.2.60 publié au Bulletin officiel du 1er juin 2020. Parallèlement à cela, quatre décrets loi ont été adoptés, le premier avait décrété l’état d’urgence sanitaire sur l’ensemble du territoire national jusqu’au 20 avril 2020 à 18h00, le second a prorogé cet état d’urgence jusqu’au 20 mai 2020, le troisième l’a prorogé à son tour au 10 juin et le quatrième l’a enfin prorogé jusqu’au 10 juillet 2020.
Préalablement à l’adoption des textes susvisés, les pouvoirs publics, en la personne du Ministère de l’Intérieur, sont intervenus, dans l’urgence, pour émettre des décisions administratives visant à limiter la propagation du Covid-19.
En date du 16 mars 2020, le Ministère de l’Intérieur émet un communiqué diffusé à travers la presse, mais dont la version originale est introuvable, par le biais duquel il annonce la fermeture de tous les lieux publics « non indispensables » à savoir les cafés, restaurants, cinémas, théâtres, salles de concert, clubs, gymnases, bains maures, salles de jeux et les stades de proximité jusqu’à nouvel ordre, et ce à partir du lundi 16 mars à 18 heures.
On nous apprend que cette procédure de fermeture ne concerne pas les marchés, les magasins et supermarchés de vente de produits alimentaires ni les restaurants qui fournissent des services de livraison à domicile. Suite à cette décision administrative, toutes entreprises ayant pour activité des business non indispensables ont dû fermer.
En date du 19 mars 2020 et toujours à travers les médias, le Ministère de l’Intérieur déclare l’état d’urgence sanitaire avec restriction de la circulation, applicable à compter du 20 mars 2020 à 18 heures.
Suite à ces décisions, les centres commerciaux ont été fermés sauf en ce qui concerne les commerces indispensables. Se pose ainsi la question de l’exigibilité, ou non, des loyers dus, dans le cadre d’un contrat de bail d’un local situé ou non dans un centre commercial, et fermé suite aux décisions des autorités.
La pandémie Covid-19, corres pond-elle à un cas de force ma jeure?
La première question qui se pose est de savoir si la pandémie Covid-19 peut être qualifiée de cas de force majeure, au sens de l’article 269 du Dahir formant Code des Obligations et Contrats qui dispose que : « La force majeure est tout fait que l’homme ne peut prévenir, tel que les phénomènes naturels (inondations, sécheresses, orages, incendies, sauterelles), l’invasion ennemie, le fait du prince, et qui rend impossible l’exé cution de l’obligation. N’est point considé rée comme force majeure la cause qu’il était possible d’éviter, si le débiteur ne justifie qu’il a déployé toute diligence pour s’en prémunir ».
Au regard de la définition susvisée, la pandémie Covid-19 correspond bel et bien à la définition de l’article 269 du DOC. En effet, la décision réglementaire de fermeture de certains commerces :
• Est un fait du prince
• Est due à un phénomène naturel qu’un être humain ne peut pas empêcher et qui n’a pu être évité ;
• N’est pas due à une défaillance antérieure de l’une quelconque des parties aux contrats de bail et enfin
• Rend impossible l’exécution du bail.
Il en résulte que, compte tenu de ses risques élevés et de la menace de décès, la pandémie Covid-19 compromet, sérieusement, la conduite des affaires dans les locaux objets des baux visés par la décision de fermeture et met en danger l’activité des locataires.
Quid des effets des décisions de fermeture sur l’exécution desdits baux ?
L’article 652 du DOC dispose que : «Les faits de l’administration publique, légalement accomplis, qui diminuent notablement la jouissance du preneur, tels que les travaux exécutés par l’administration, ou les arrêtés pris par elle, autorisent le preneur à poursuivre, selon les cas soit la résolution du bail, soit une réduction proportionnelle du prix ; ils peuvent donner ouverture aux dommages contre le locateur, s’ils ont pour cause un fait ou une faute imputable à ce dernier. Le tout, sauf les stipulations des parties .»
En application de cet article et en l’absence de stipulation contractuelle contraire, un locataire est en mesure de s’abstenir de verser les loyers à compter de la date de fermeture des locaux ayant fait objet de la décision de fermeture.
En effet :
• La décision des autorités est une décision administrative accomplie légalement ;
• Ladite décision empêche le locataire de jouir et d’exploiter les locaux loués ;
• “La réduction proportionnelle du loyer” consiste en l’abstention de paiement des loyers pendant toute la durée de l’effet de la décision de fermeture. En outre, cette lecture juridique se trouve corroborée par les dispositions de l’article 338 du Dahir formant Code des obligations et Contrats, lequel dispose que : « Lorsque l’inexécution de l’obligation provient d’une cause indépendante de la volonté des deux contractants, et sans que le débiteur soit en demeure, le débiteur est libéré, mais n’a plus le droit de demander la prestation qui serait due par l’autre partie. Si l’autre partie a déjà rempli son obligation, elle a le droit, selon les cas, d’en répéter la totalité ou une partie, comme indue. »
Cet article confirme la position ci-dessus dans la mesure où la décision de fermeture des locaux dispense :
• Le propriétaire de son obligation d’assurer la jouissance des lieux ;
• Le locataire de son obligation de payer les loyers. Il en résulte qu’en vertu dudit article toujours et sous réserve des stipulations contractuelles contenues dans les baux, deux scénarii se présentent devant le locataire :
• Soit il demandera la résolution du bail ;
• Soit il sera en mesure de poursuivre la réduction proportionnelle des loyers, ce qui devrait aboutir à une decision de justice l’affranchis sant de verser les loyers pendant toute la durée de la fermeture comme décrit ci-dessus ;
En résumé :
1. La Covid-19 présente les caractéristiques de la force majeure ;
2. Les loyers des locaux ayant fait objet d’une décision administrative de fermeture ne sont pas exigibles durant toute la période de fermeture fixée par voie réglementaire ;
3. Le locataire peut soit maintenir le bail et réclamer l’affranchissement des loyers durant ladite période de fermeture ou poursuivre la résolution du bail.
Il est certain que si le contrat de bail comporte des stipulations contraires aux dispositions légales susvisées, il est indispensable d’en étudier le contenu et la teneur, préalablement, à la prise de toute décision. F *Avocate au Barreau de Casablanca Si le contrat de bail comporte des stipulations contraires aux dispositions légales susvisées, il est indispensable d’en étudier le contenu et la teneur, préalablement, à la prise de toute décision.
Si le contrat de bail comporte des stipulations contraires aux dispositions légales susvisées, il est indispensable d’en étudier le contenu et la teneur, préalablement, à la prise de toute décision.
Rédigé par Kawtar JALAL
Avocate au Barreau de Casablanca
Cabinet d’Avocats Agouram & Jalal
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