FACTS:

On December 29, 1976, Paciencia Gonzales Asuncion and the Heirs of Felipe F. Asuncion filed an application for the registration of nine parcels of land in Bambang, Bulacan, Bulacan. They claimed to have registerable titles to the lands through inheritance, accretion, and open and notorious possession for at least 30 years.

The Solicitor General opposed the application, arguing that the lands were inalienable forest lands of the public domain. Other individuals also opposed the application.

In 1986, the applicants' motion to admit an amended application for eleven parcels of land was granted by the trial court. In 1996, the applicants and other oppositors entered into a compromise agreement, which the trial court approved despite the Solicitor General's objection.

The trial court later dismissed the application for two parcels of land and approved the registration of five others. The Solicitor General received a copy of the decision on July 27, 2001, and filed a motion for reconsideration on August 2, 2001. The trial court denied the motion, ruling that it was pro forma and filed out of time.

The Solicitor General then filed a notice of appeal, which the trial court dismissed for being filed out of time. The Solicitor General petitioned the Court of Appeals to annul the trial court's orders, but the appellate court dismissed the petition, ruling that the trial court did not abuse its discretion in rejecting the motion for reconsideration and notice of appeal.

ISSUES:

1. Whether or not the Court of Appeals committed a reversible error of fact in misapprehending petitioner's motion for reconsideration as a pro forma motion for new trial.

2. Whether or not the Court of Appeals committed a reversible error of law in holding that petitioner's motion for reconsideration was a pro forma motion for reconsideration.

3. Whether or not the Court of Appeals committed a reversible error of law in holding that an erroneous characterization of a motion for reconsideration as pro forma is a mere error of judgment.

RULING:

1. The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the trial court did not commit a reversible error in declaring petitioner's motion for reconsideration as pro forma. The Court further held that the motion for reconsideration lacked an affidavit of merit and merely reiterated the petitioner's previous arguments. The Court concluded that the motion for reconsideration did not toll the reglementary period to appeal and therefore, the trial court did not abuse its discretion in rejecting the petitioner's prayer to present evidence and file an appeal.

PRINCIPLES:

• A motion for reconsideration must comply with the procedural requirements, such as including an affidavit of merit and raising new arguments or grounds for reconsideration.

• A motion for reconsideration that merely reiterates previous arguments and lacks an affidavit of merit may be considered as pro forma.

• A pro forma motion for reconsideration does not toll the reglementary period to appeal.