August 28, 2019
SEC-OGC OPINION NO. 29-19
WHOLLY OR PARTLY NATIONALIZED ACTIVITY; ANTI-DUMMY LAW
Ambica International Corporation
9 Amsterdam Extension, Merville Park
Subdivision, Parañaque City
Attention: Atty. Gener C. Sansaet and Atty. Marie Madeleine L.R. Victorino
Counsels for Ambica International Corporation
Gentlemen :
This refers to your letters dated 20 March 2019 and 30 July 2019 requesting an opinion on whether Ambica International Corporation ("Ambica") is engaged in a wholly or partly nationalized activity under the Foreign Investments Act 1 ("FIA") and other applicable laws, and whether it is covered by the Anti-Dummy Law. 2 HTcADC
In your letter, you stated that Ambica is primarily engaged in the importation and trading of pharmaceutical products, cosmetics and food products with paid up capital of Php63,500,000.00. It is further disclosed that Ambica's customers are as follows: 1. Distributors — top local pharmaceutical companies from various regions with their own sales and marketing force; 2. Chain drugstores; 3. Hospitals — both private and government; 4. Wholesalers — top wholesalers who sell to independent drugstores; 5. Independent drugstores; and 6. Private and Government institutions.
To determine whether Ambica is engaged...
