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.

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