treatment and continued failure to pay his sickness wages amounting to
US$4,800.00, he was constrained to provide for his own medical expenses; (5) his
injuries constituted permanent and total disability which, under POEA
Memorandum Circular No. 5, series of 1994, would make petitioners liable for
disability benefits under his employment contract in the amount of US$60,000.00;
and (6) his injury or disability was directly and proximately due to the direct and
vicarious acts of negligence of petitioners and their agents. Respondent prayed
that judgment be rendered, declaring petitioners liable to reimburse his medical
and hospital expenses in the total amount of P103,969.00 and to pay him disability
benefits in the amount of US$60,000.00, sickness wages of US$4,800.00,
compensatory damages of US$604,800.00 (this amount was reduced to
US$13,370.00 in his Position Paper), moral damages of P1,100,000.00, and
exemplary damages and attorney’s fees in such an amount as the labor arbiter may
deem proper.
In his Position Paper,15[15] respondent sought reimbursement of his medical
expenses and asserted that petitioners are liable to pay him sickness wages,
compensatory damages, moral damages, and attorney's fees. However, respondent
withdrew his claim for disability benefits with reservation to re-file a complaint
should there be a recurrence of his injury.
15[15] Id. at 52-62.