L’articolo 1 co. 2 del D.Lgs. 23/2015, nel delineare il campo di applicazione del regime di tutele nel caso di licenziamento illegittimo per i lavoratori assunti con contratto a tutele crescenti a far data dal 7 marzo 2015, stabilisce che “le disposizioni di cui al presente decreto si applicano anche nei casi di conversione, successiva all’entrata in vigore del presente decreto, di contratti a tempo determinato o di apprendistato in contratto a tempo indeterminato”.
Tale norma è stata sin da subito oggetto di commenti e interpretazioni, in particolare con riferimento al termine conversione, utilizzato dal Legislatore con riferimento a contratti a tempo determinato o di apprendistato, stipulati prima del 7.3.2015, e poi appunto convertiti in contratti a tempo indeterminato.
L’interpretazione più estensiva, e certamente più immediata, ha inteso la disposizione in argomento come se Legislatore, nell’utilizzare il termine conversione, avesse voluto riferirsi a tutte le ipotesi di trasformazione di contratti a termine in essere in contratti a tempo indeterminato e ciò non solo ai fini dell’applicazione delle Tutele Crescenti, ma anche per il beneficio degli esoneri contributivi previsti dalla Legge di Stabilità del 2015.
Secondo questa impostazione, quindi, il Legislatore avrebbe fatto riferimento a una generica conversione del contratto a termine, intesa non solo come conversione operata da un Giudice in forza di un regime sanzionatorio applicabile in presenza di contratti nulli o illegittimi, ma anche come prosecuzione senza soluzione di continuità di rapporti a tempo determinato avviati prima del 7 marzo 2015, oppure di contratti di apprendistato proseguiti a seguito del mancato esercizio della facoltà di recesso al termine del periodo di formazione.
Come detto, tuttavia, questa interpretazione non tiene conto del dato letterale della norma e dà per pacifica una intenzione del Legislatore che, alla luce di un’analisi più approfondita, non sembrerebbe tale e cioè l’intenzione di utilizzare il termine conversione in senso generico, quale sinonimo di trasformazione del contratto a tempo determinato e di prosecuzione del rapporto di apprendistato dopo il termine del periodo di formazione.
Va infatti innanzitutto considerato che i principi e i criteri fissati dalla Legge Delega n. 183 del 10.12.2014 per l’applicazione del contratto a Tutele Crescenti fanno riferimento inequivocabilmente ad un parametro oggettivo, che è quello delle nuove assunzioni. E certamente, in termini giuridici, non possono essere considerate nuove assunzioni né le trasformazioni senza soluzione di continuità di contratti a termine, né tantomeno la mera prosecuzione dei contratti di apprendistato dopo il periodo di formazione.
Il termine conversione, infatti, assume, nell’ambito dell’ordinamento giuridico italiano, un preciso significato tecnico. Esso è utilizzato sia dall’art. 1424 cod. civ. per i casi di un contratto nullo il quale può produrre gli effetti di un contratto diverso del quale contenga i requisiti di sostanza e forma, sia dall’art. 32 co. 5 della L. 183/2010 (c.d Collegato Lavoro), come sanzione specificamente prevista dalla legge nelle ipotesi di contratto a tempo determinato nullo, perché stipulato in violazione dei requisiti formali o sostanziali necessari per l’apposizione del termine al contratto di lavoro.
Secondo questa interpretazione restrittiva, quindi, l’impiego del termine conversione da parte del Legislatore non avrebbe dunque nulla di generico ma, anzi, assumerebbe un significato tecnico ben preciso, richiamando testualmente il regime sanzionatorio previsto dalla legge in presenza di determinati vizi formali e sostanziali nella stipulazione di contratti di lavoro a termine e di apprendistato.
Sul punto, la giurisprudenza di merito si è divisa e non ha fornito una interpretazione unanime.
Ad esempio, il Tribunale di Roma, con sentenza n. 75870 del 6.8.2018, ha ritenuto di non condividere l’interpretazione, definita più lineare, del termine conversione, ricomprendente cioè tutte le ipotesi di trasformazione di un contratto a termine in un contratto a tempo indeterminato. Secondo il Tribunale di Roma, quindi, le Tutele Crescenti sono applicabili in quei casi in cui un contratto a tempo determinato, stipulato prima del 7.3.2015, subisca una conversione per via giudiziale e non, al contrario, nelle ipotesi di semplice trasformazione, conseguente ad una prosecuzione di fatto del rapporto oltre il termine contrattuale, ovvero a seguito di una manifestazione esplicita di volontà.
Di segno opposto invece la recente sentenza n. 383/2019 del Tribunale di Parma, secondo la quale le Tutele Crescenti sarebbero applicabili nel caso di conversione per volontà negoziale di un contratto a tempo determinato, stipulato prima del 7.3.2015, in un contratto a tempo indeterminato, mentre tale regime di tutele non sarebbe applicabile nel caso in cui la conversione sia stata disposta in sede giudiziale, a seguito della dichiarazione di nullità del termine. Questo perché, secondo il Tribunale di Parma, la conversione operata in sede giudiziale di un contratto a termine determina la costituzione di un rapporto a tempo indeterminato con efficacia ex tunc, cioè dall’origine, con conseguente applicazione del regime di stabilità reale di cui all’art. 18 Statuto dei Lavoratori.
Alla luce delle divergenze interpretative illustrate, torna quindi utile il suggerimento contenuto nella Circolare n. 1983 del 9.3.2015 di Confindustria, secondo cui sarebbe altamente consigliabile, in tutte le possibili ipotesi di trasformazione di un rapporto a tempo determinato in uno a tempo indeterminato, la formale chiusura del precedente rapporto a termine, per poi avviare subito dopo un nuovo rapporto a tempo indeterminato.
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