Title
All Oceans Maritime Agency, Inc. vs. National Labor Relations Commission
Case
G.R. No. 78700
Decision Date
Sep 3, 1991
Seafarer Bongoyan claimed unpaid wages; All Oceans alleged unauthorized fund withdrawals. NLRC ruled Bongoyan owed $241.61, All Oceans owed $3,749.65, netting $3,508.04 due to Bongoyan. SC affirmed with interest.
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Case Digest (G.R. No. 78700)

Facts:

Engagement and Service of Regulo Bongoyan

  • All Oceans Maritime Agency, Inc. engaged Regulo Bongoyan as the master of the vessel Sarpindo Pribumi for a 12-month period at a monthly salary of US $1,430.00.
  • Bongoyan served from November 4, 1980, to December 8, 1981, completing his term.

Complaint Filed by Bongoyan

  • In August 1982, Bongoyan filed a complaint with the Philippine Overseas Employment Administration (POEA) seeking recovery of US $3,749.65 for unpaid salaries, overtime pay, annual leave pay, and home leave pay.

Defense by All Oceans

  • All Oceans claimed that Bongoyan made unauthorized drawings from crew provision funds totaling US $6,107.59.
  • Bongoyan partially repaid US $1,250.00, leaving a balance of US $1,107.94 after offsetting his claim.

POEA Decision

  • The POEA ruled that All Oceans was estopped from holding Bongoyan liable for unauthorized drawings because it had acquiesced to the overdrawings by not objecting for months.
  • All Oceans was ordered to pay Bongoyan US $3,749.65.

NLRC Decision

  • The National Labor Relations Commission (NLRC) affirmed the POEA decision but rejected the estoppel argument, finding that All Oceans had questioned the advances.
  • The NLRC held that Bongoyan could not be held accountable due to doubts about his actual liability, citing Article 1279 of the Civil Code, which requires debts to be demandable and liquidated for set-off.

Bongoyan’s Advance-Payment System

  • Upon assuming command, Bongoyan discovered that provisions for November 1980 had already been consumed.
  • To address this, he adopted an "advance-payment" system, drawing funds from succeeding months to cover the shortfall.
  • This system continued until March 1981, with some irregularities in June 1981 and December 1981.

Allegations of Misappropriation

  • All Oceans accused Bongoyan of:
    1. Drawing funds twice for June 1981 provisions.
    2. Collecting the full allocation for December 1981 despite serving only until December 8, 1981.
  • All Oceans claimed a total loss of US $6,107.59 due to these actions.

Bongoyan’s Payments and Liability

  • Bongoyan turned over US $523.86 to his successor and made two payments totaling US $2,264.70 to All Oceans.
  • After deductions, Bongoyan’s liability to All Oceans was reduced to US $241.61.

Amount Due to Bongoyan

  • The NLRC found that All Oceans owed Bongoyan US $3,749.65 for unpaid overtime, annual leave pay, home leave pay, and salary.
  • After deducting Bongoyan’s liability, the net amount due was US $3,508.04.

Issue:

  1. Whether Bongoyan was liable for unauthorized drawings from crew provision funds.
  2. Whether All Oceans was estopped from holding Bongoyan accountable for the overdrawings.
  3. Whether the set-off of claims between Bongoyan and All Oceans was valid under Article 1279 of the Civil Code.
  4. Whether the NLRC committed grave abuse of discretion in its ruling.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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