Exhibit 8

                               August 29, 2003

Board of Directors
Oriental Financial Group Inc.
Professional Offices Park
1000 San Roberto Street
San Juan, Puerto Rico 00926

                  RE:      SERIES B PREFERRED STOCK

Ladies and Gentlemen:

         We have acted as counsel for Oriental Financial Group Inc., a Puerto
Rico corporation (the "Company"), in connection with a Registration Statement
on Form S-3 filed with the Securities and Exchange Commission on August 28,
2003 (the "Registration Statement"), for the purpose of registering under the
Securities Act of 1933, as amended (the "Act"), up to 1,380,000 shares of
Noncumulative Monthly Income Preferred Stock, Series B, $1.00 par value per
share, of the Company.

         We have examined the prospectus contained in the Registration
Statement (the "Prospectus") and have reviewed the discussion of certain United
States and Puerto Rico income tax considerations of the proposed offering
described in the Prospectus (the "Tax Discussion") appearing under the captions
"Taxation," "Puerto Rico Taxation" and "United States Taxation." We have also
reviewed such other documents and instruments and have examined such questions
of law as we have considered necessary or appropriate for the purpose of this
opinion. In





Oriental Financial Group Inc.
August 29, 2003
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addition, we have relied on certificates of officers of the Company as to
certain factual matters.

         The Tax Discussion represents our opinion regarding the material
United States and Puerto Rico tax consequences described therein.

         Our opinion is based upon the review of the Prospectus and of
applicable United States and Puerto Rico income tax statutes, regulations,
rulings and decisions, as now in full force and effect. A change in any of the
foregoing could require a change in our opinion. In addition, our opinion
pertains only to the accuracy of the statement of law contained in the Tax
Discussion. As to statements of fact, we are relying upon your representation
that such factual statements are true and accurate as of the date hereof.

         We are members of the Bar of the Commonwealth of Puerto Rico. The
opinions expressed herein are limited to the laws of the Commonwealth of Puerto
Rico and any applicable federal laws. We do not purport to be experts in, or to
render any opinions with respect to the laws of any state or jurisdiction other
than the laws of the Commonwealth of Puerto Rico and the federal laws of the
United States of America.

         We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to us under the heading "Taxation"
in the Prospectus contained in the Registration Statement. In giving the
foregoing consent, we do not thereby admit that we are in the category of
persons whose consent is required under Section 7 of the Act.

                                                Very truly yours,