The United States vs. H.N.

Bull GR L-5270Jan 15, 1910

Facts:

On the 2nd of December 1908, a steamship vessel engaged in the transport of animals named Standard commanded
by H.N. Bull docked in the port of Manila, Philippines. It was found that said vessel from Ampieng, Formosa
carried 677 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 ship 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. The offense, assuming that it originated in Formosa, which the Philippines would have no jurisdiction,
continued until it reached Philippine territory which is already under jurisdiction of the Philippines. Defendant is
thereby found guilty, and sentenced to pay a fine with subsidiary imprisonment in case of insolvency, and to pay
the costs.

No court of the Philippines has jurisdiction over any crimes committed in a foreign ship on the high seas, but the
moment it entered into territorial waters, it automatically would be subject to the jurisdiction of the country.
Every state has complete control and jurisdiction over its territorial waters. The Supreme Court of the United
States has recently said that merchant vessels of one country visiting the ports of another for the purpose of
trade would subject themselves to the laws which govern the ports they visit, so long as they remain.