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.

Select target paragraph3