Mr. Alvaro C. Torio

August 18, 1981 Mr. Alvaro C. Torio Assistant General Manager Batong Buhay Gold Mines, Inc. 5th Flr., Executive Building Center Buendia Ave. Extension, Makati Avenue Makati, Metro-Manila Dear Sir: This is with regards to your letter dated April 20, 1981 asking the opinion of this Commission on the legality of your corporation's intended reduction of the par value of its common stocks from P0.01 to P0.007 without reducing its present authorized capital stock of P200 million. Under existing policies, this Commission does not allow the reduction of the par value of any class of stocks lower than P0.01 except if the purpose of the corporation for reduction is to wipe off their deficit. As to the question of reduction of your corporation's authorized capital, the Commission holds that there is no need of reducing the corporation's authorized capital stock in cases of reduction of its par value of shares, the corporation can just reclassify its shares by amending its articles of incorporation. Please be guided accordingly. LibLex Very truly yours, (SGD.) CORAZON I. MORANDO Officer-In-Charge Corporate and Legal Department