Though, having denied that there was no demand letter served on April 10, 2000, however, the

prosecution positively alleged and proved that the questioned demand letter was served upon the
accused on April 10, 2000, that was at the time they were attending Court hearing before Branch
I of this Court. In fact, the prosecution had submitted a Certification issued by the other Branch
of this Court certifying the fact that the accused were present during the April 10, 2010 hearing.
With such straightforward and categorical testimony of the witness, the Court believes that the
prosecution has achieved what was dismally lacking in the three (3) cases of Betty King, Victor
Ting and Caras evidence of the receipt by the accused of the demand letter sent to her. The Court
accepts the prosecutions narrative that the accused refused to sign the same to evidence their
receipt thereof. To require the prosecution to produce the signature of the accused on said
demand letter would be imposing an undue hardship on it. As well, actual receipt
acknowledgment is not and has never been required of the prosecution either by law or
jurisprudence. - Eumelia R. Mitra vs. People of the Philippines and Felicisimo S. Tarcelo,
G.R. No. 191404, July 5, 2010

After the summons had returned unserved to petitioner because "there [was] no person in the
said given address," the trial court allowed the publication of the summons to petitioner. Other
modes of serving summons may be done when justified. Service of summons through other
modes will not be effective without showing serious attempts to serve summons through
personal service. Thus, the rules allow summons to be served by substituted service only for
justifiable causes and if the defendant or respondent cannot be served within reasonable time.
The pertinent facts and circumstances attendant to the service of summons must be stated in
the proof of service or Officers Return; otherwise, any substituted service made in lieu of
personal service cannot be upheld. This is necessary because substituted service is in derogation
of the usual method of service. It is a method extraordinary in character and hence may be used
only as prescribed and in the circumstances authorized by statute. Here, no such explanation was
made. Failure to faithfully, strictly, and fully comply with the requirements of substituted service
renders said service ineffective. Aurora de Pedro vs. Romasan Development Corp, G.R. No.
194751, November 26, 2014