G.R. No. 87585 . March 27, 1990.
BLUE MANILA, INC., petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, PHILIPPINE OVERSEAS EMPLOYMENT ADMINISTRATION and EMMANUEL E. ABELLANEDA, respondents.

FACTS

Petitioner Blue Manila, Inc., a recruitment agency, deployed private respondent Emmanuel Abellaneda as a seaman for a six-month contract with its foreign principal, Seatrans Offshore Ltd. Abellaneda’s contract was preterminated. He filed a complaint with the Philippine Overseas Employment Administration (POEA) for unpaid wages covering his service from November 11, 1986, to January 28, 1987, during which he worked on a different vessel after the lease on his original ship expired. He also claimed entitlement to war zone bonuses and overtime pay. The petitioner, in its defense, argued that any monetary claim had been extinguished by the cash advances received by Abellaneda and the costs it incurred for his repatriation airfare and the airfare of his replacement.
The POEA ruled in favor of Abellaneda, computing his unpaid wages and ordering Blue Manila to pay him US$3,017.54 (after deducting cash advances), plus US$725.64 representing the airfare ticket for his replacement, and attorney’s fees. The National Labor Relations Commission (NLRC) affirmed this decision in toto. Blue Manila then filed this petition for certiorari, initially contesting only its solidary liability with the foreign principal. However, in this proceeding, it highlighted a patent error in the POEA’s dispositive portion.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in affirming a POEA decision containing a clear mathematical and logical error in its dispositive portion regarding the deduction of airfare costs.

RULING

Yes, the NLRC committed grave abuse of discretion. The Court found a plain and clerical error in the POEA decision’s dispositive portion, which the NLRC failed to correct upon affirmation. The body of the POEA decision correctly noted that since Abellaneda voluntarily preterminated his contract, the cost of his repatriation airfare (US$725.64) was equitably deductible from his salary. Furthermore, it correctly stated that he should not be liable for his replacement’s airfare under the governing contract. Paradoxically, the dispositive portion ordered the petitioner to pay Abellaneda the amount for his replacement’s airfare, instead of deducting his own repatriation cost.
While the Solicitor General argued this specific error was waived for not being raised in the appeal to the NLRC, the Supreme Court exercised its prerogative to correct plain errors under Section 7, Rule 51 of the Rules of Court. The Court held that overlooking such a mathematical inconsistency, which would allow a party to unjustly profit from an evident mistake, would be contrary to substantial justice and the spirit of the Labor Code, which mandates the resolution of cases on their merits without strict adherence to technicalities. Consequently, the petition was granted. The dispositive portion was modified to deduct the cost of Abellaneda’s repatriation airfare (US$725.64) from the awarded unpaid salaries, thereby correcting the erroneous award of his replacement’s airfare.