January 7, 1999

John Hancock Declaration Trust
   on behalf of John Hancock V.A. Strategic Income Fund
101 Huntington Avenue
Boston, MA 02199

Ladies and Gentlemen:

In connection  with the filing of a registration  statement under the Securities
Act of 1933, as amended (the "Act"), on Form N-14, with respect to the shares of
beneficial  interest of John Hancock V.A.  Strategic Income Fund (the "Fund"), a
series of John Hancock Declaration Trust (the "Trust"), a Massachusetts business
trust, it is the opinion of the undersigned that these shares when issued,  will
be legally issued, fully paid and non-assessable.

In  connection  with this opinion it should be noted that the Trust is an entity
of  the  type  generally  known  as  a  "Massachusetts  business  trust."  Under
Massachusetts  law,  shareholders of a Massachusetts  business trust may be held
personally  liable  for the  obligations  of the  trust.  However,  the  Trust's
Declaration  of Trust  disclaims  shareholder  liability for  obligations of the
Trust and indemnifies any shareholder of the Fund, with this  indemnification to
be paid solely out of the assets of the Fund. Therefore,  the shareholder's risk
is limited to  circumstances in which the assets of the Fund are insufficient to
meet the obligations asserted against the Fund's assets.

The  undersigned  hereby  consents to the filing of a copy of this opinion as an
exhibit  to the  Trust's  registration  statement  on Form  N-14  and  with  the
Securities and Exchange Commission.

Sincerely,


/s/Alfred Ouellette
Alfred Ouellette
Attorney and Assistant Secretary
John Hancock Advisers, Inc.