Short answer. Yes. Under Rule 13, Section 15 of the Rules of Court, service by accredited courier is complete upon actual receipt by the addressee, or after at least two delivery attempts by the courier, or five calendar days after the first attempt — whichever comes earliest. Two genuine failed attempts can therefore complete service even without actual receipt.
What the law says
Service by accredited courier is complete upon actual receipt by the addressee, or after at least two attempts to deliver by the courier service, or upon the expiration of five calendar days after the first attempt to deliver, whichever is earlier.
Rule 13, Section 15 — Completeness of service. Read the full provision →
Three triggers, earliest one wins
Rule 13, Section 15 fixes the moment courier service becomes legally complete: upon actual receipt by the addressee, or after at least two attempts to deliver by the courier service, or upon the expiration of five calendar days after the first attempt to deliver, whichever is earlier. That gives three independent triggers. Actual receipt completes service at once. Failing that, two delivery attempts complete it. And even with only one attempt, service completes anyway once five calendar days pass from that first attempt. The rule takes whichever of the three happens first, so a party cannot stall a case simply by never being available when the courier calls.
Why refusing the courier does not help
The design is deliberate. Deadlines in litigation start running from service, and if completeness depended entirely on the addressee choosing to receive the document, a party could freeze the other side's case by dodging deliveries indefinitely. The two-attempt and five-day triggers close that door: once the courier has genuinely tried twice, or once five calendar days have run from the first genuine attempt, the law treats the document as served and the associated periods begin. For the party being served, the practical lesson is blunt — an unclaimed pleading is still a served pleading, and the period to respond can expire while the envelope sits at the courier's depot.
The attempts still have to be real
Completion by failed attempts assumes the courier actually attempted delivery at the correct address of record. The rule speaks of attempts to deliver by the courier service, which supposes the courier went to the right place — the address the party or counsel is required to keep updated with the court and the other parties. In a dispute over whether service was complete, what matters is the proof: the courier's records of when and where each attempt was made. A party who was served at a stale address it never updated is in a weak position to complain, while a serving party relying on attempts at a plainly wrong address is not really within the rule at all.
Courier service compared with the other modes
The same section sets different completion points for each mode of service, and the differences are worth knowing. Personal service is complete upon actual delivery, with no waiting period. Registered mail completes upon actual receipt or five calendar days after the first postmaster's notice, whichever is earlier. Ordinary mail completes ten calendar days after mailing. Electronic service completes at transmission, but is not effective if the sender learns the document never reached the addressee. Accredited courier sits in the middle: faster to complete than ordinary mail, but with the two-attempt safeguard replacing the postmaster's notice. If you are calculating a response deadline from a courier-served pleading, the date of the first attempt — not the date you finally picked it up — may be what controls.