JUSTICE MARTIN VILLARAMA, JR.: MOTION FOR RECONSIDERATION PRO FORMA

      The Supreme Court has held that mere reiteration of issues already passed upon by the court does not automatically make a motion for reconsideration pro forma. What is essential is compliance with the requisites of the Rules. 

          Indeed, in the cases where a motion for reconsideration was held to be pro forma, the motion was so held because (1) it was a second motion for reconsideration, or (2) it did not comply with the rule that the motion must specify the findings and conclusions alleged to be contrary to law or not supported by the evidence, or (3) it failed to substantiate the alleged errors, or (4) it merely alleged that the decision in question was contrary to law, or (5) the adverse party was not given notice thereof. (FERNANDO V. GONZALES VS. COMELEC, G.R. NO. 192856, MARCH 8, 2011, VILLARAMA, JR., J.).