G.R. No. 193374 - Heirs of the Late Ecarma vs. Court of Appeals

Petitioners are the heirs of the late Gerry Ecarma: Avelina Suiza-Ecarma, Dennis Ecarma, Jerry Lyn Ecarma Pena, Antonio Ecarma, and Natalia Ecarma Sangalang.
Respondents are the Court of Appeals (CA) and Renato A. Ecarma, the administrator in intestate proceedings for the estate of Arminda vda. de Ecarma (decedent).
The case involves a dispute among the heirs over the partition of properties inherited from decedent Arminda, who was married to Natalio Ecarma (now both deceased).

During the marriage of Natalio and Arminda, several properties were acquired, comprising four main properties: Kitanlad, Cuyapo, and two lots in Lala.
After Natalio’s death in 1970, the heirs executed an Extrajudicial Settlement of Estate covering the four properties, assigning Arminda an undivided two-ninths share and each of the seven children an equal one-ninth share.
Despite this agreement, no physical division of the properties was effected; the properties remained in co-ownership (pro indiviso) at Arminda’s death in 1983.

Renato Ecarma filed intestate proceedings for Arminda’s estate in 1990, with appointment as Special Administrator in 1991.
After years of conflict and opposition from Gerry Ecarma, Renato filed a Project of Partition on 9 March 2005, proposing:

Kitanlad property division longitudinally into seven equal parts with lots allocated by lot;
Partition of Cuyapo and Lala properties into seven equal parts, with some parts to be donated to the Armed Forces of the Philippines (AFP).

The Regional Trial Court (RTC), Branch 220, approved the Project of Partition by Order dated 28 July 2005.

Gerry Ecarma and Rodolfo Ecarma opposed the partition, arguing that the project was not feasible, detrimental, not in accordance with the decedents’ wishes, and that the RTC lacked jurisdiction to partition parts not comprising Arminda’s estate.
The RTC denied their motions for reconsideration, maintaining the approval of the partition.

Gerry Ecarma died during the proceedings; petitioners (his heirs) substituted him and filed an Appellants’ Brief at the CA.
The CA dismissed the appeal for failure to comply with Section 13, Rule 44 of the Rules of Court, citing omissions such as absence of subject index, table of cases and authorities, statement of case, statement of facts, and page references to the record.
Petitioners filed a Supplemental Appellants’ Brief and Motion for Reconsideration, which the CA also denied for non-compliance with procedural requirements.
Petitioners then filed this Petition for Certiorari under Rule 65 of the Rules of Court, alleging grave abuse of discretion by the CA.

Whether the CA gravely abused its discretion amounting to lack or excess of jurisdiction in dismissing petitioners’ appeal for procedural defects.

Whether petitioners’ failure to comply with Section 13, Rule 44 of the Rules of Court warranted dismissal of their appeal.

Whether the RTC, Branch 220, had jurisdiction over the partition of the subject properties and whether the Order of Partition was justified.

Whether petitioners’ absolute opposition to the partition of the co-owned properties was legally sustainable.