**Facts:**
Arminda vda. de Ecarma and Natalio Ecarma, who predeceased her in 1970, had seven children and acquired several properties during their marriage. Upon Natalio’s death, an Extrajudicial Settlement divided four properties among Arminda and her children. The heirs remained co-owners of these properties until Arminda’s death in 1983.
1. **Initial Legal Proceedings:**
– Following Arminda’s death, Renato Ecarma’s petition for probate of her will was dismissed by the RTC, Branch 86, Quezon City.
– Renato filed intestate proceedings (SP PROC. No. Q-90-6332) on May 18, 1990.
– Renato was appointed Special Administrator on January 30, 1991.
2. **Conflict and Proposed Partition:**
– Due to ongoing conflicts over property division and use, Renato proposed a partition in 2005.
– The RTC, Branch 220 approved the partition on July 28, 2005, with specific plans for the Kitanlad, Cuyapo, and Lala properties.
3. **Motions for Reconsideration:**
– Gerry and Rodolfo Ecarma objected to the partition on grounds of impracticality and incorrectness regarding the decedents’ wishes and jurisdiction.
– The RTC denied these motions.
4. **Appeals to the CA:**
– Gerry filed a Notice of Appeal and Record on Appeal.
– The Court of Appeals dismissed the appeal due to deficiencies in the appellants’ brief, failure to meet requirements of Section 13, Rule 44 of the Rules of Court.
**Issues:**
1. **Procedural and Substantive Compliance:**
– Was the dismissal of the appeal by the CA due to procedural deficiencies a grave abuse of discretion?
– Should the Supreme Court treat the petition under Rule 45 instead of Rule 65?
2. **Jurisdiction and Partition Validity:**
– Did the RTC have jurisdiction to order the partition of properties?
– Were the objections by Gerry Ecarma and other heirs against the partition valid and lawful?
**Court’s Decision:**
1. **Petition Denied:**
– The Supreme Court found no grave abuse of discretion by the CA in dismissing the appeal for procedural deficiencies, in line with Section 1(f), Rule 50. As the petitioners did not file the correct remedy of appeal by certiorari under Rule 45, the petition for certiorari under Rule 65 was dismissed.
2. **Merits of Partition Order:**
– **Jurisdiction Validity:** The properties in question were validly part of the conjugal estate dissolved upon Natalio’s death, partitioned into co-ownership after Arminda’s death.
– **Court-Sanctioned Partition:** The RTC’s order for equal division was upheld. The Court emphasized the statutory rights of co-owners and compulsory heirs under Articles 494 and 1083 of the Civil Code permitting the termination of co-ownership.
**Doctrine:**
– **Adherence to Procedural Rules:** Appeals must meet specified content requirements. Failure leads to dismissal, intended to ensure orderly justice.
– **Co-ownership Termination Right:** Co-owners cannot be forced into perpetual co-ownership; they have a right to demand partition unless otherwise explicitly restricted by agreements or legal provisions.
**Class Notes:**
– **Appeal Requirements:** Section 13, Rule 44 of the Rules of Court stipulates clear content needs for appellants’ briefs including subject indexes, statements of case and facts, and page references.
– **Co-ownership Termination (Article 494, Civil Code):** Owners may demand partition at any time unless restricted by agreement or law.
– **Partition Process (Articles 495, 498, Civil Code):** Properties must be divided unless indivisible. If indivisible, the sale can be ordered.
– **Succession Laws (Articles 774, 777):** Heirs gain rights at decedent’s death, inheriting equally subject to debts and legitime (Article 887).
**Historical Background:**
– **Estate Disputes:** Such cases reflect common conflicts among heirs involving inherited property rights and management.
– **Civil Code Provisions Role:** The case reinforces principles within Philippine succession laws and co-ownership rules, emphasizing lawful processes and heir obligations.
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