Roger v. Navarro

Summary

This case involves procedural and substantive issues in a replevin action for motor vehicles. Karen Go sued Roger Navarro to recover vehicles leased under agreements signed by her husband Glenn Go as manager of her sole proprietorship, Kargo Enterprises. The Supreme Court ruled that Karen Go is the real party-in-interest as the registered owner of the business, and that the business constitutes conjugal property presumed under Family Code Article 116. The Court held that either spouse may bring actions for recovery of conjugal property without joining the other as indispensable party, applying Civil Code Article 487 on co-ownership. The decision clarifies that sole proprietorships cannot sue in their own name, but the registered owner has standing, and that prior demand is not required for replevin actions. The petition was denied, affirming Karen Go's right to maintain the replevin action.