Mr. Espiritu M. Guillermo, Sr.

October 3, 1996 Mr. Espiritu M. Guillermo, Sr. Municipal Federation of Senior Citizens Associations of Bacoor, Cavite c/o Office of MSWDO, Bacoor Cavite S i r : This refers to your letter dated September 25, 1996 requesting opinion on the query posed therein. As stated, you have organized the Municipal Federation of Senior Citizens Associations of Bacoor, Cavite which you and the members intend to register with the Securities and Exchange Commission in order to obtain a legal personality. However, the newly SEC registered Provincial Federation of Senior Citizens Associations of Cavite of which all Municipal Federations of Senior Citizens Associations of the cities/municipalities of Cavite are members, claims that there is no need to register your association and the same can use the Provincial Federation's registration as authority for any legal purpose. Hence, you are requesting opinion or advice on the matter. A component member of an association need not be registered separately from the mother association . However, if the former wants to have a separate and distinct juridical personality from that of the latter, it has to be incorporated and registered in accordance with the Corporation Code so that it can acquire an independent status. A separate incorporation/registration enables the former to exercise such powers, rights and privileges of a corporation granted under the Corporation Code, such as the power to adopt its own by-laws to govern its corporate affairs and the power to exist independently as such without the intervention of the mother association. Very truly yours, (SGD.) FE ELOISA C. GLORIA Associate Commissioner