This case has been cited 1 times or more.
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2013-10-23 |
BRION, J. |
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| Section 13, Rule 13 of the Rules of Court provides that if service is made by registered mail, proof shall be made by an affidavit of the person mailing of facts showing compliance with Section 7, Rule 13 of the Rules of Court and the registry receipt issued by the mailing office. However, the presentation of an affidavit and a registry receipt is not indispensable in proving service by registered mail. Other competent evidence, such as the certifications from the Philippine Post Office, may establish the fact and date of actual service. These certifications are direct and primary pieces of evidence of completion of service. [27] | |||||