GENERAL PRINCIPLE: NOTICE TO THE COUNSEL OF RECORD MEANS NOTICE TO THE CLIENT. HOWEVER, THE OMISSION OR NEGLIGENCE OF SAID COUNSEL BINDS THE CLIENT.

As a general rule, when a party is represented by a counsel, service of orders and notices must be made upon said counsel of record and notice to the client and to any other lawyer, not the counsel of record, is not notice in law.

The exception to this rule is when service upon the party himself has been ordered by the court. In case therefore the service was already made on the counsel of record at his given address, notice to client himself is no longer necessary (SPOUSES DOMINGO M. BELEN, ET. AL., vs. HON. PABLO R. CHAVEZ, et al. G.R. No. 175334, March 26, 2008, Second Division, Tinga, J.).

          In other words, when a party is represented by a counsel, notices of all kinds, including motions, pleadings and orders, must be served on the counsel of record himself, and notice to the said counsel is binding on the client.

Be that as it may, the omission or negligence of counsel binds the client.  Thus, the neglect or failure of counsel to inform the client of an adverse judgment resulting in the loss of his right to appeal is not a ground for setting aside a judgment, valid and regular on its face. 

This is more true if the client did not make a periodic check on the progress of her case. Otherwise, there would be no end to a suit, so long as a new counsel could be employed who would allege and show that the prior counsel had not been sufficiently diligent, experienced, or learned.

This was precisely the tenor of the pronouncement of the Supreme Court in Mapagay vs. People, where it was observed that there was no showing that petitioner had constantly followed up her case with the counsel of record.  Petitioner did not even bother to call or personally go to the court to verify the progress of her case. Undeniably, petitioner did not exercise diligence in pursuing her case (MAPAGAY vs. PEOPLE, G.R. No. 178984, August 19, 2009, Chico-Nazario, J.).

This doctrine is of course without prejudice to the exceptions laid down in the several pronouncements of the Supreme Court. 

In Salonga vs. Court of Appeals, 269 SCRA 534 and San Miguel Corporation vs. Laguesma, 236 SCRA 595, the High court emphasized that where the negligence of a counsel amounts to a deprivation of due process for the client or results to serious injustice, the said negligence of counsel does not bind the client.