sc.judiciary.gov.ph/jurisprudence/2012/november2012/176834.pdf
"x x x.
The general rule is that a client is bound by the acts, even mistakes, of his counsel in the realm of procedural technique. The basis is the tenet that an act performed by counsel within the scope of a “general or implied authority” is regarded as an act of the client. While the application of this general rule certainly depends upon the surrounding circumstances of a given case, there are exceptions recognized by this Court: “(1) where reckless or gross negligence of counsel deprives the client of due process of
law; (2) when its application will result in outright deprivation of the client’s liberty or property; or (3) where the interests of justice so require.”
x x x."
