Can a person who has not been shown to be incompetent challenge the failure to appoint a guardian ad litem for the first time on appeal?

Here, the court was not under a mandatory, sua sponte, duty to appoint a guardian ad litem because father was not a minor, he was not a person for whom a conservator had been appointed, and he was not shown to be incompetent, within the meaning of Code of Civil Procedure section 372, subdivision (a). We have not found any cases holding that a person who has not been shown to be incompetent may challenge the failure to appoint a guardian ad litem for the first time on appeal. Because father is presumed to be competent absent proof to the contrary⁴ (People v. Ramos (2004) 34 Cal.4th 494, 507 [ref. proceedings to determine competency]), and because the court was not required to appoint a guardian ad litem sua sponte, father bears the responsibility to protect his own

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