Commodore Francis T. Mallillin

May 4, 1995 Commodore Francis T. Mallillin Office of the Deputy Chief of Staff for Material Development, J9 General Headquarters, Armed Forces of the Philippines Camp General Emilio Aguinaldo, Quezon City S i r : This refers to your letter of April 25, 1995 requesting this Office to furnish you with documents showing the real owner and stockholders of Creser Precision Systems, Inc.,especially the share of Ms. Jeannette P. Tolentino who claimed to be a majority stockholder thereof. The Corporation Code provides in part: "SECTION 74. Books to be kept; stock transfer agent . ... xxx xxx xxx Stock corporation must also keep a book to be known as the " stock and transfer book " in which must be kept a record of all stocks in the names of the stockholders alphabetically arranged; the installments paid and unpaid on all stock for which subscription has been made and the date of payment of any installments; a statement of every alienation, sale or transfer of stock made, the date thereof, and by and to whom made; and such other entries as the by-laws may prescribe. The stock and transfer book shall be kept in the principal office of the corporation or in the office of its stock transfer agent and shall be open for inspection of any director or stockholder of the corporation at reasonable hours on business days. xxx xxx xxx. (Emphasis supplied) Thus, to be able to give a definite information as to the present ownership of the corporation, much would depend on the identities of the stockholders as appearing in the stock and transfer book of the corporation which is kept in the principal office of the corporation. The stock and transfer book is the best evidence to establish stock ownership in a corporation. Considering therefore that the Commission is not in possession of the stock and transfer book of the corporation, we cannot furnish you a definite information on the matter. The function of registration of stock ownership or transfer thereof in the stock and transfer book of the corporation pertains to that of the corporate secretary or transfer agent. Any controversy pertaining to ownership of stocks may be raised to the Commission by filing a formal complaint with the Securities Investigation and Clearing Department of this Commission pursuant to the provisions of PD 902-A, as amended. Very truly yours, (SGD.) FE ELOISA C. GLORIA Associate Commissioner