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 under a six-month contract with its foreign principal, Seatrans Offshore Ltd. Abellaneda’s contract was preterminated, leading him to file a complaint with the Philippine Overseas Employment Administration (POEA) for unpaid wages and benefits. He claimed entitlement to unpaid salaries from November 11, 1986, to January 28, 1987, after he was reassigned to a different vessel following the expiration of the lease on his original ship. 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, ordering Blue Manila to pay him US$3,017.54 as balance of unpaid salaries (less cash advances) and, erroneously, an additional US$725.64 representing the airfare cost for his replacement. The National Labor Relations Commission (NLRC) affirmed the POEA decision in toto. In its petition for certiorari before the Supreme Court, Blue Manila initially challenged its solidary liability with the foreign principal but later highlighted a patent inconsistency: the POEA’s dispositive portion awarded Abellaneda the replacement’s airfare, whereas its own textual analysis stated that a seaman should not be liable for such cost under the standard contract.

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

The Supreme Court granted the petition, modifying the award. The Court found that the NLRC’s affirmance of the POEA decision, despite a plain error in its dispositive portion, warranted correction. The POEA’s own findings established that Abellaneda unilaterally preterminated his contract, making it equitable for the employer to deduct his repatriation airfare from his unpaid salary, pursuant to the governing contract. However, the dispositive portion incorrectly ordered Blue Manila to pay Abellaneda the airfare cost for his replacement—an amount he never expended and which, under the standard terms, should not be charged to him.
The Solicitor General conceded this error but argued it was waived as not raised in the appeal to the NLRC. The Court rejected this technicality, invoking the exception under Rule 51, Section 7 of the Rules of Court, which allows the correction of plain and clerical errors even if not assigned. The mathematical miscalculation was a plain error that, if uncorrected, would result in a manifest injustice, allowing Abellaneda to receive an unwarranted windfall. The Court emphasized that labor proceedings must be decided based on substantive justice, not technicalities, as mandated by Article 221 of the Labor Code.
Consequently, the Court modified the dispositive portion to deduct the repatriation airfare (US$725.64) from the salary award, rectifying the inconsistency and ensuring Blue Manila was properly credited for this expense. The award for attorney’s fees was upheld. The decision underscores the Court’s authority to correct obvious errors to achieve equitable results, aligning formal dispositions with substantive findings.