SERVICE OF PAPERS AND JUDGMENTS:

On many occasions, the Court has strictly construed the requirements of the proper service of papers and judgments. Both in Heirs of Delos Santos v. Del Rosario, G.R. No. 139167, 29 June 2005, 462 SCRA 98 and Tuazon v. Molina, No. L-55697, 26 February 1981, 103 SCRA 365, the service of the trial courts decision at an adjacent office and the receipt thereof by a person not authorized by the counsel of record was held ineffective. Likewise, the service of the decision made at the ground floor instead of at the 9^th floor of a building in the address on record of petitioners counsel, was held invalid in PLDT v. NLRC, No. L-60050, 213 Phil. 362 (1984). In these cases, there was no constructive service of the decision even if the service was made at the offices adjacent to the address on record of the parties counsels and even if the copies eventually found their way to persons duly authorized to receive them. (See also Adamson Ozanan Educational Institution, Inc. v. Adamson University Faculty and Employees Association, G. R. No. 86819, 9 November 1989, 179 SCRA 279; BPI-Family Savings Bank, Inc. v. Court of Appeals, G. R. No. 94925, 22 April 1991, 196 SCRA 242 cited in SPOUSES DOMINGO M. BELEN, ET. AL., vs. HON. PABLO R. CHAVEZ, et al. G.R. No. 175334, March 26, 2008, Second Division, Tinga, J.).