Mrs. Amelia M. Barros

June 19, 1981 Mrs. Amelia M. Barros University of the Philippines Quezon City Dear Mrs. Barros: This has reference to your letter dated June 4, 1981 requesting opinion on whether or not the Philippine Center for Economic Development Hotel, owned and operated by the Philippine Center for Economic Development (PCED) which was created by PD 453 dated May 13, 1974, should register with the Securities and Exchange Commission. P.D. 453 vests upon the PCED a distinct corporate personality (Section 1) and authorizes it, among others, "to carry on any activity and to have and exercise all the power conferred by law on a private or government-owned or controlled corporation, and to do any and all of the acts and things herein set forth to the same extend as juridical persons could do, and in any part of the world, as principal, factor, agent, or otherwise, either alone or in syndicate or otherwise in corporation with any person, entity, syndicate, partnership, or association or corporation, domestic or foreign" (Section 2 [g]). In view thereof, our answer to your query is in the negative. Please be advised accordingly. cdll Very truly yours, (SGD.) ROSARIO N. LOPEZ Director Corporate and Legal Department