This Google Books search finds a page that says this:
74. Legendre's theorem
${}\qquad\qquad{}$ If each of the angles of a spherical triangle whose
sides are small when compared with the radius of the sphere
be diminished by one third of the spherical excess, the triangle
may be solved as a plane triangle whose sides are equal to
the sides of the spherical triangle, and whose angles are these
reduced angles.
"Spherical excess" I take to mean the amount by which the sum of the three angles exceeds a half-circle.
Similarly imprecise statements are found by additional googling. The sides are "small when compared to", etc., and the solution is approximate. So I'm thinking there should be something maybe with a Landau little-o, saying as the size goes to $0$, the error goes to $0$ like some power of the size. Maybe.
Does anyone know of a mathematically precise statement of this proposition?