Facts:

The case involves Blue Manila, Inc. as the petitioner and the National Labor Relations Commission (NLRC), Philippine Overseas Employment Administration (POEA), and Emmanuel E. Abellaneda as respondents. The events leading to the case began in May 1986 when Emmanuel Abellaneda applied for overseas work with Blue Manila, Inc. On September 16, 1986, he was deployed to Bahrain to serve as an AB/Oiler on the vessel "GRAY-VANGUARD" for a six-month contract at a basic salary of US$335 per month, with an additional war zone bonus and overtime pay. The vessel entered a war zone on October 3, 1986, and remained there until November 10, 1986, when the crew was informed that the lease on the vessel had expired. Abellaneda was offered a position on another vessel, MV SEATRANS 23, which he accepted on November 11, 1986, intending to fulfill the remainder of his contract. However, he did not receive his salary and other benefits during this period, leading him to take cash advance...

Facts:

Recruitment and Employment

• The petitioner, Blue Manila, Inc., is a recruitment agency that deployed the private respondent, Emmanuel E. Abellaneda, to work as a seaman on the vessel "GRAY-VANGUARD" owned by its foreign principal, Seatrans Offshore Ltd.
• Abellaneda was hired for a six-month contract with a basic salary of US$335 per month, including a 100% war zone bonus and overtime pay.
• On October 3, 1986, the vessel entered a war zone, and on November 10, 1986, the crew was informed that the lease of the vessel had expired. Abellaneda was then offered to work on another vessel, MV SEATRANS 23, owned by the same principal, which he accepted.

Unpaid Wages and Disembarkation

• From November 11, 1986, Abellaneda was not paid his salary and other benefits. He took cash advances amounting to $512.48 for his family's sustenance.
• On January 28, 1987, Abellaneda voluntarily disembarked in Bahrain. He demanded his unpaid wages from the Operations Manager of Seatrans, Mr. Horst Jager, but was instead charged with simulated offenses and briefly incarcerated.
• Mr. Jager promised to pay Abellaneda's salary in Manila, but upon his return, Capt. Mangabat refused to pay, claiming the money had not been remitted.

POEA Decision

• The Philippine Overseas Employment Administration (POEA) ruled in favor of Abellaneda, ordering Blue Manila, Inc. to pay:
  1. US$3,017.54 as unpaid salaries, less cash advances.
  2. US$725.64 as the airfare for Abellaneda's replacement.
  3. 10% of the total award as attorney's fees.
• The POEA failed to deduct the airfare for Abellaneda's return trip, which was paid by the employer, and erroneously ordered the payment of the replacement's airfare.

NLRC Affirmation

• The National Labor Relations Commission (NLRC) affirmed the POEA decision in toto. Blue Manila, Inc. appealed, arguing that it was merely an agent of a disclosed principal and should not be held solidarily liable with the foreign principal.

Issue:

1. Whether the NLRC committed grave abuse of discretion in affirming the POEA decision despite a clear conflict between the findings of fact and the dispositive portion of the decision.
2. Whether Blue Manila, Inc. should be held solidarily liable with its foreign principal for the money judgment in favor of Abellaneda.
3. Whether the POEA erred in ordering the payment of the replacement's airfare instead of deducting the repatriation expenses from Abellaneda's unpaid wages.

Ruling:

• The Supreme Court granted the petition for certiorari and modified the POEA and NLRC decisions.
• The Court corrected the mathematical error in the POEA decision, ruling that the airfare for Abellaneda's return trip should be deducted from his unpaid wages, and the replacement's airfare should not be charged to him.
• The dispositive portion of the decision was modified as follows:
  1. Blue Manila, Inc. is ordered to pay Abellaneda US$3,017.54, less cash advances and the airfare for his repatriation (US$725.64).
  2. Blue Manila, Inc. is ordered to pay 10% of the total award as attorney's fees.

Ratio:

• (Unlock)