In re Estate of Pangelinan — Supreme Court of Guam Holds Pro Se Executor Need Not Retain Counsel to Petition for Letters Testamentary
The Supreme Court of Guam unanimously reversed a probate court’s refusal to appoint a named executor, holding that neither a law license nor retained counsel is required to petition for letters testamentary under the Guam Probate Code, and that the statutory grounds of “improvidence” or “want of understanding” cannot be established solely by the petitioner’s failure to retain an attorney — even where the probate court acknowledged a severe attorney shortage on the island.