ReactOS MUST work on non-ACPI systems.
On ACPI systems, ACPI will enumerate all your serial ports, even
non-standard ones.
On all systems (ACPI and non-ACPI), standard serial ports will be
probed to test their existence.
I think, to correctly enumerate com ports in this situation, you need
to remove enumeration
code from pnp routines. What do you think about creating something like
SerialEnumerateComPorts() routine
and call it from DriverEntry? If you are not working on this now, I can
try to implement it. The enumeration process
is described in "Enumerating Legacy COM Ports" article from DDK.