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May 24, 2012

名目上の取締役

名目上の取締役の責任とは何か。取締役の登記があっても取締役業務の執行実績がない者に,取締役の責任を問えるのか。
一人しかいない代表取締役が他人に業務を任せて,第三者や会社に損害を負わせた場合は,善管注意義務を怠った者として責任を負うことに異論はあるまい。(大地判昭43.12.24,最判昭44.11.26など)。本来なすべき業務を怠っているからである。
ここで取り上げるのは,そうした業務懈怠の事案ではなく,取締役であっても元々名前を貸したにすぎないことを会社関係者も知っていた場合の問題である。会社内部で代表権のないことが知られていても,外部の人が知らなければ,会社は表見代表取締役として会社が行った行為として評価される(会社法354条)。
夫が代表権もないのに実権を握り,妻が名前だけの社長になることもあろう。その場合,夫は代表取締役ではないから,代表者としての商法上の責任は負わない。(旧商法266条の3。なお,有限会社法30条の3につき,東京地判昭43.12.27は悪意又は重大な過失を否定した。)しかし,社長の名をかたって会社と取引させた不法行為責任はあるし,妻は放置した善管注意義務違反を,もし社長の名刺などを使っていれば会社は取引上の責任を問われる。
 代表権のない取締役は,取締役会を通じて代表権する取締役を監視監督しなければならないが,取締役会に挙げられない事項について監督権限を行使するのは無理である。取締役会で意見を述べ,担当業務とされた事項を行うことが取締役の責任の限界となる。
取締役間でも相互に監視監督の義務が生じる。ある業務を担当した取締役の提案に対し,他の取締役が明確に反対の意見を述べたときは,漫然と職務を怠ったことにならない。
 最高判昭和48年5月22日は,「株式会社の取締役会は会社の業務執行につき監査する地位にあるから,取締役会を構成する取締役は,会社に対し,取締役会に上程された事柄についてだけ監視するにとどまらず,代表取締役の業務執行一般につき,これを監視し,必要があれば,取締役会を自ら招集し,あるいは招集することを求め,取締役会を通じて業務執行が適正に行なわれるようにする職務を有するものと解すべきである。」という。
事案は,3人で共同出資して会社を設立し,しかも3人とも営業に携っていたが,会社の業務執行全体については代表取締役一人に任せきりにしていた。代表取締役の職務違反行為に対して平取締役の任務解怠が問われた。実質的(形式的ではない)取締役の一般的監視義務違反が認められたもので,これは,いわゆる名目的平取締役の一般的監視義務違反の有無そのものについての判決ではない。その意味で,この判決後も,非常に多い名目的平取締役の監視義務違反の具体的要件いかんの問題は残されていた。

 その後も,事案を考慮して,結果的には監視義務違反の成立を否定する下級審判例が見られる。具体的事情としては,病気による休養中であった(前橋地高崎支判昭49.12.26),会社業務に実際に携わったことはなく,また問題の約束手形の振出にも関与していなかった(札幌地判昭51.7.30),東京に本店にある会社の取締役に,名目的・形式的に就任した者が,清水市に居住してもっぱら自己が代表者である他の会社の業務執行に従事していた(東京地判昭53.3.16),会社は代表取締役一人が経営の実権を掌握し,他の取締役や社員の容啄を許さない独断専攻による経営であった(大高判昭53.4.27)などがある。
これらの4つの判例事案では,取締役会またはこれに代わるべきものは一度も開催されたことがなかった。

 最高判昭和55年3月18日は,取締役は職務を行うにつき悪意又は重大な過失があったときは第三者に生じた損害を賠償する責任を負うとしている。事案は,非常勤のいわゆる社外重役として名目的に取締役に就任していた者について,社長が代金支払いの見込みもなく商品を買入れた場合,名目上の取締役が社長の業務の執行をまったく監視・監督をせず,また,取締役会の招集を行なわなかったことから,売主に対する損害賠償責任を認めたものである。
 過去の判例は,報酬を受けていないことなどを理由に,通常の取締役より責任を緩和していた。そのような判例は,現在の会社法制定以前に,小規模なものも含め株式会社すべてに3人以上の取締役を置くことが義務付けられていた時代のものである。いまの会社法の下では,取締役は1名でも足り(会社法326条),取締役を3人以上置く必要もないので,員数あわせする必要もなく,名目取締役にもより厳しい判断がなされる可能性がでてきた。また,責任を問われるかどうかにかかわらず,名目上の取締役として就任することを会社と合意した者であっても,他の取締役や業務執行一般に対する監視義務を負うことに変わりない。
現在は,取締役の員数につき下限がないので,名目取締役の責任を軽減する方向には判断されにくい状況にある。
今後の方向としては,取締役会で事前の監視が可能であったにもかかわらず監視権発動に必要な措置を講じなかったことが立証される限り,監視義務違反の責任を負わなければならないとされることが増えるだろう(前出大高判昭53.4.27参照)。
その他,取締役が取締役会に規則的に出席して監視義務をつくすべきことは当然であるので,不断の監視まで要求されていない平取締役とはいえ,最判昭48.5.22の事案のように,会社業務に全く無関心で,設立以来開かれたことのない取締役会の招集を求めることもなく,正当な理由(病気・出張など)もなく長期にわたって取締役会を欠席するなど,取締役としての職務を全く果たしていない場合には,重大な任務解怠があったものとして,代表取締役の職務違反行為に関する監視義務違反の責任が認められるべきとする説がある。大高判昭54.3.23(判時931号119頁)は,出資もせず,報酬も受けず,殆ど名目上の取締役として名を連ねたにすぎず,会社業務について専門的知識を有しないことを理由に,悪意・重過失を否定したが,こうした判決に反対する学者もいる。

 最近の判例として,最二小判平22.1.29(金融商事判例1348号)がある。
会社分割して企業グループの中核となった新設設立会社が,グループに属するほかの会社に金員を貸付け,その会社の社長が借り入れの保証をした。社長には実権がなく,代表者印,銀行取引印,預金通帳は親会社に取り上げられていた。経営方針も親会社が決めていた。売上げ目標の設定や実績の報告が求められた。社長の勤務実態は従業員同然だった。問題の借り入れも,親会社が一方的に決めた。社長に就任したものの,資金繰りが限界を超え,借入や保証をするようになった。とうとう,辞任を申し出た。代役が社長に就任したが,会社は営業停止に至った。親会社の社命で社長の就任したものは反抗できないから辞めるしかない。辞めるまでに個人保証した債務の責任を負うのか。一審は保証債務の請求が権利濫用になるとして責任を否定し,二審は社長就任時にはまだ破綻必至とは認められなかったとして,責任を認めた。そして最高裁は,請求は権利濫用に当たるとして,保証責任を否定した。
権利濫用論ではなく,名目的取締役だから責任がない,とは言えなかったであろうか。
代表者印,銀行取引印も持たされない社長は,社長の実権を行使できない。親会社の社命で社長に就任したに過ぎず,名前だけの社長である。個人保証も社長という立場で半ば強制された。保証債務は,社長の権限があっての債務だろう。義務だけ負う片面的社長は社長といえない。名目だけの社長,ロボット社長は,社長であるがゆえに負わされる個人責任はない。あるいは社長責任ではなく個人責任の問題だという反論があるかもしれない。
しかし,個人として負う責任に限らず,取締役としての責任についても,必ず善管注意義務違反が生じるとは限らない。嫌なら辞めればいいという議論もあろうが,辞められないこともあるだろう(大王製紙関連会社役員4人の22日東京地裁証言)。なによりも,社長や取締役としての業務を執行していたか,できる立場にあったか,それができないのに責任だけ負わされる不利な立場になかったか,生け贄社長・取締役では,善管注意義務違反の前提条件が失われるのではないか,と思う。
第三者に対する関係でも,悪意・重過失(429条)がいえなくなるだろう。
頼まれ役員というのもあった。(東京地判平8.6.19)
有限会社の創業者が資金繰りに失敗した。別会社の金を資金繰りに流用した。パチンコのグループ内で資金流用していた。別会社は倒産し,役員が訴えられた。
設立時に創業者から頼まれて取締役になっただけだったから,役員報酬もなく,出資持分もなかった。仕事はパチンコ台の釘打ち程度。景品納入業者が役員を訴えても,損害発生と取締役の業務との間には因果関係が認められない。この理屈で行くと,創業者の責任を問えそうだが,どうだろう。

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