GR 78700; (September, 1991) (Digest)
G.R. No. 78700 September 3, 1991
ALL OCEANS MARITIME AGENCY, INC., and GOLDEN PEAK MARITIME AGENCY, LTD., petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, PHILIPPINE OVERSEAS EMPLOYMENT ADMINISTRATION, and REGULO BONGOYAN, respondents.
FACTS
Petitioner All Oceans Maritime Agency, Inc. employed private respondent Regulo Bongoyan as master of the vessel M/V Sarpindo Pribumi for a fixed term. After completing his contract, Bongoyan filed a complaint with the POEA to recover unpaid salaries, overtime, and leave pay totaling US $3,749.65. In defense, All Oceans claimed that Bongoyan had made unauthorized drawings from crew provision funds amounting to US $6,107.59, and after crediting partial payments and his monetary claim, argued he still owed a balance.
The POEA ruled in favor of Bongoyan, finding All Oceans estopped from claiming liability due to its acquiescence to the drawings. The NLRC affirmed the award but on different grounds, refusing to allow compensation or set-off between the claims. The NLRC held that Bongoyan’s liability for the drawings was not liquidated or certain, citing doubts arising from his advance-payment method for provisions and his turnover of a balance to his successor.
ISSUE
Whether the National Labor Relations Commission committed grave abuse of discretion in affirming the award to Bongoyan and in refusing to allow compensation between the parties’ reciprocal monetary claims.
RULING
The Supreme Court found no grave abuse of discretion but modified the monetary award. The Court clarified that legal compensation under Article 1279 of the Civil Code requires that the debts be liquidated and demandable. Upon examination, Bongoyan’s admitted debt to All Oceans for excess drawings was quantified. The evidence showed that from the alleged total deficit for December 1981 provisions, amounts Bongoyan turned over to his successor and cash payments he made to All Oceans should be deducted. This computation established his liquidated liability at US $241.61.
Conversely, it was factually established that All Oceans owed Bongoyan US $3,749.65 for various benefits. Since both sums were liquidated and demandable, legal compensation was proper. The Court held that the NLRC erred in stating compensation could not apply, but its ultimate decision to award Bongoyan was correct, albeit for the wrong reason. The reciprocal obligations extinguished each other to the concurrent amount. Therefore, from the amount owed to Bongoyan (US $3,749.65), his debt to All Oceans (US $241.61) was deducted, leaving a net award of US $3,508.04. The NLRC decision was affirmed with modification, fixing petitioners’ liability at the peso equivalent of that amount.