1997, executed by respondent; and that respondent is not entitled to moral and
exemplary damages and attorney's fees.
By way of counterclaim, they sought
recovery of litigation expenses, actual damages, and attorney's fees in an amount
not less than P20,000.00 and, also, exemplary damages in an amount at the
discretion of the labor arbiter.
In their Supplement to Position Paper,18[18] petitioners averred that
respondent sought another employment with Tara Trading Shipmanagement, Inc.
(for and in behalf of Amethyst Shipping Co.), on board M/V Luna Azul, for a
period of twelve (12) months, with a basic monthly salary of US$967.00 at 48
hours of work weekly, overtime pay of US$535.00/month (US$6.24 per hour
beyond 105 hours), and vacation leave with pay of 3 days a year (or US$98.00 a
month), as evidenced by his Contract of
Employment, 19[19] Seafarer Info-
Sheet20[20] and POEA Overseas Employment Certificate.21[21]
Seaman
SIGNED IN THE PRESENCE OF:
_____________________________
18[18] Id. at 93-95.
19[19] Id. at 96.
20[20] Id. at 97.
21[21] Id.