Supreme Court of Guam

In the Matter of the Estate of Jose Aguon Pangelinan

July 15, 20262026 Guam 5

Summary

The court held that Schacher was not required to retain legal counsel or possess a law license to petition for probate and seek appointment as executor. The probate court abused its discretion by treating Schacher's lack of counsel and law license as proof of incompetence and by finding no substantial evidence of improvidence or want of understanding. The court reversed and remanded with instructions to appoint Schacher as executor, while explaining that counsel would be required for any later quiet-title action pursued for the benefit of other beneficiaries.