CASE DIGEST: US vs Bull, 15 Phil 7

Case Title: US vs Bull, 15 Phil 7

Subject Matter: Applicability of Art. 2 of the Revised Penal Code

Facts:

On December 2, 1908, a steamship vessel engaged in the transport of animals named Stanford commanded by H.N. Bull docked in the port of Manila, Philippines. It was found that said vessel from Ampieng, Formosa carried 674 heads of cattle without providing appropriate shelter and proper suitable means for securing the animals which resulted for most of the animals to get hurt and others to have died while in transit.

This cruelty to animals is said to be contrary to Acts No. 55 and No. 275 of the Philippine Constitution. It is however contended that cases cannot be filed because neither was it said that the court sitting where the animals were disembarked would take jurisdiction, nor did it say about ships not licensed under Philippine laws, like the ships involved.

Issue:

Whether or not the court had jurisdiction over an offense committed on board a foreign ship while inside the territorial waters of the Philippines.

Held:

Yes. When the vessel comes within 3 miles from the headlines which embrace the entrance of Manila Bay, the vessel is within territorial waters and thus, the laws of the Philippines shall apply. A crime committed on board a Norwegian merchant vessel sailing to the Philippines is within the jurisdiction of the courts of the Philippines if the illegal conditions existed during the time the ship was within the territorial waters - regardless of the fact that the same conditions existed when the ship settled from the foreign port and while it was on the high seas,

In light of the above restriction, the defendant was found guilty and sentenced to pay a fine of two hundred and fifty pesos with subsidiary imprisonment in case of insolvency, and to pay the costs.