You can always add another SplitContainer in the panel of the first one to achieve that.
I think this two panel restriction is a cleaner design, because each SplitContainer can have a horizontal or vertical splitter, and you can design deeply nested splits this way, which would be hard to do if a SplitContainer had >2 panels.
+----------------------------------+ | 1 3 | | 1 344444444| | 1 3 | | 1 3 | | 122222222222222222| | 1 | | 1 | | 1 | | 1 | | 1 | +----------------------------------+
(the numbers represent one splitter) |