NAVARRO V.

ESCOBIDO

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 Navarro’s 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 Go’s
(husband) leasing business is a conjugal property and thus ordered Karen Go to file
a motion for the inclusion of Glenn Go as co-plaintiff 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.

HELD: 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 Navarro’s 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 effectively 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.