CASE DIGEST: US v. Fowler, 1 Phil. 614

Title: US v. Fowler, 1 Phil. 614

Subject Matter: Applications of the provisions of Art. 2 of the Revised Penal Code

Facts:

In August 12, 1901, the defendants were accused of the theft of 16 champagne bottles worth 20 dollars while on board the vessel, “Lawton”. The counsel for defendants alleged to the Court of First Instance of Manila that they were without jurisdiction over the crime charged. Since it happened in the high seas and not in the city of Manila or in the territory in which the jurisdiction of the court extends, they asked that the case be dismissed.

Issue:

Whether or not the Court of First Instance of Manila has jurisdiction over the criminal case theft committed on board while navigating on high seas on a vessel not registered in the Philippines.

Held:

No. The Philippine court has jurisdiction over the crime of theft committed on high seas on board a vessel not registered or licensed in the Philippines. The English Rule states that such crimes are triable in our country when crimes are committed on board a foreign vessel sailing from a foreign port and which enters the Philippine waters. In the case at bar, the vessel Lawton was navigating the high seas at the commission of the crime. Given the location of the vessel at the time, such act is not triable within our jurisdiction.