You can look at the chain of title at the recorder's office; if the property states it is held in trust (usually it will state the trustee's name, and the name and date of the trust) then that means it is part of the trust estate.
That would allow the property to pass outside of probate.
If the property is not held in trust, then it is possible that the recipient obtained the property unlawfully and if the property was to pass via the laws of intestate succession (no will or trust, so it goes to the next of kin, in equal amounts) the heir can sue to void the transaction and then petition to open probate.
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Information provided is for educational purposes only. Consultation with a personal attorney is always recommended so your particular facts may be considered. Thank you and take care.