NAVARRO VS ESCOBIDO

606 SCRA 1

TOPIC: Real Parties in Interest, Indispensable Parties

FACTS:

Respondent Karen T. Go filed two complaints before the RTC for replevin and/or sum of money with
damages against Navarro. In these complaints, Karen Go prayed that the RTC issue writs of replevin for the seizure
of two (2) motor vehicles in Navarros possession. In his Answers, Navarro alleged as a special affirmative defense
that the two complaints stated no cause of action, since Karen Go was not a party to the Lease Agreements with
Option to Purchase (collectively, the lease agreements) the actionable documents on which the complaints were
based. RTC dismissed the case but set aside the dismissal on the presumption that Glenn Gos (husband) leasing
business is a conjugal property and thus ordered Karen Go to file a motion for the inclusion of Glenn Go as co-plaintif
as per Rule 4, Section 3 of the Rules of Court. Navarro filed a petition for certiorari with the CA. According to Navarro,
a complaint which failed to state a cause of action could not be converted into one with a cause of action by mere
amendment or supplemental pleading. CA denied petition.

ISSUE:

Whether or not Karen Go is a real party in interest.

RULING:

YES. Karen Go is the registered owner of the business name Kargo Enterprises, as the registered owner of
Kargo Enterprises, Karen Go is the party who will directly benefit from or be injured by a judgment in this case. Thus,
contrary to Navarros contention, Karen Go is the real party-in-interest, and it is legally incorrect to say that her
Complaint does not state a cause of action because her name did not appear in the Lease Agreement that her
husband signed in behalf of Kargo Enterprises.

Glenn and Karen Go are efectively co-owners of Kargo Enterprises and the properties registered under this
name; hence, both have an equal right to seek possession of these properties. Therefore, only one of the co-owners,
namely the co-owner who filed the suit for the recovery of the co-owned property, is an indispensable party thereto.
The other co-owners are not indispensable parties. They are not even necessary parties, for a complete relief can be
accorded in the suit even without their participation, since the suit is presumed to have been filed for the benefit of all
co-owners.

We hold that since Glenn Go is not strictly an indispensable party in the action to recover possession of the
leased vehicles, he only needs to be impleaded as a pro-forma party to the suit, based on Section 4, Rule 4 of the
Rules, which states:

Section 4.Spouses as parties. Husband and wife shall sue or be sued jointly, except as provided by law.
Even assuming that Glenn Go is an indispensable party to the action, misjoinder or non-joinder of
indispensable parties in a complaint is not a ground for dismissal of action as per Rule 3, Section 11 of the
Rules of Court.