Does a conservator have to appear before a judge in a personal injury action brought by the wife under conservatorship?

Under the terms of section 372 of the Code of Civil Procedure, when an incompetent person is a party to an action he must appear either by a guardian of the estate or by a guardian ad litem appointed by the court in which the action is pending. Although the mere fact that a conservator has been appointed does not constitute a determination that the conservatee is in any way 'insane or incompetent' (cf. Prob.Code, 1751; Schuck v. Myers,233 Cal.App.2d 151, 154(1), 43 Cal.Rptr. 215), section 372 of the Code of Civil Procedure specifically provides that 'reference to 'incompetent person' shall be deemed to include 'a person for whom a conservator may be appointed. " Under the circumstances, if the wife, being under conservatorship, had attempted to prosecute the action in her individual capacity, section 372 of the Code of Civil Procedure could have been raised against her right to bring it.