Isabela State University | ECHAGUE

College of Criminal Justice Education

ISABELA STATE UNIVERSITY

Echague Main Campus

COLLEGE OF CRIMINAL JUSTICE EDUCATION

-Criminology Program-

COMPARATIVE MODELS IN POLICING

[CRIM PROF 213] S.Y. 2020-2021

An Instructional Material

Prepared by:

REGINALD C. SIBUG
Instructor

CHAPTER 1
INTRODUCTION TO COMPARATIVE POLICE SYSTEM

COMPARATIVE MODELS IN POLICING

Reginald C. Sibug, MS CRIM. 1

Chapter’s Contents:
A. Introduction
B. Concept of Police
C. Traditional Goals of Policing
D. Ancient Policing System
E. IMPORTANT Terms:
 Comparative Police System
 Comparative Criminal Justice
 Comparative Court System
 Comparative Correctional System
 Comparative Juvenile Justice System
 International Criminal Justice
 Model System
F. Transnational Crimes
LEARNING OBJECTIVES
At the end of the lesson, students should be able
to:
1. Gain general insights about the basic
concept of comparative models in
policing.
2. Explain the concept of police and
differentiate the different concepts
and theories of policing.
3. Enumerate and explain the traditional
goals of Policing
4. Identify and understand the various
ancient policing system around the
world.
5. define and understand the meaning of
Comparative Police System; Criminal
Justice; court system; Correctional
System mean; Juvenile Justice System;
International Criminal Justice; Model
System
6. define and understand the meaning of
Transnational Crime;
7. gain insights on the different
transnational crimes like Drug
trafficking, human trafficking,
Cybercrime, terrorism and Money
laundering.
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
A. INTRODUCTION
The study of comparative models in policing,
comparative police system, comparative criminal justice
and law is a fairly new field and has corresponded with
rising interest in a more established field, comparative
criminology. However, in this chapter, we will present
some issues which will bring you to discover ideas
useful in the conceptualization of successful crime
control policies.
Chapter I contains the salient features of
comparative models in policing. It is focused on the
basic terms and topics covered on this subject prior to
the actual comparison of the police models.
“The modern police service is a varied, multi-layered,
responsive institution working to ensure the safety of
Citizens” – UK Home Office
The role of a modern police organization is laid
down succinctly in the above quote appearing in the
web page of UK Home Office. The first idea that comes to
our mind when we hear the term “Police” is the idea of a
dominant personality who symbolizes the power of the
State and criminal justice administration system. On the
one hand people view police as a protector of civil
liberties and on the other hand police is viewed as a
symbol of brute force of state which oppresses the
legitimate protests with force.
Dictionaries define Police as the governmental
department charged with the regulation and control of
the affairs of a community, now chiefly the department
established to maintain order, enforce the law, and
prevent and detect crime.
Policing is one of the most important of the
functions undertaken by every sovereign government.
For the state machinery, police is an inevitable organ
which would ensure maintenance of law and order, and
also the first link in the criminal justice system. On the
other hand, for common man, police force is a symbol of
brute force of authority and at the same time, the
protector from crime. Police men get a corporate
identity from the uniform they wear; the common man
identifies, distinguishes and awes him on account of the
same uniform. The police systems across the world have
2
 Isabela State University | ECHAGUE
College of Criminal Justice Education
developed on a socio cultural background, and for this C. TRADITIONAL GOALS OF POLICING
reason alone huge differences exist between these police
systems. The importance of the police in administration of justice
can also be shown by studying its five traditional goals
B. CONCEPT OF “POLICE” which as follows: (1) enforcement of laws; (2)
preservations of the peace; (3) prevention of crimes; (4)
protection of civil rights and liberties; and (5) providing
POLICE is the agency of a community or government
other services. The success or failure of the police in
that is responsible for enforcing the law, maintaining
achieving these goals can directly affects the works and
public order, and preventing and detecting crime.
functions of other pillars. In this regard, police pillar is
In the very broadest sense, the term POLICE refers considered as the BACKBONE of the criminal justice
to the internal organization or regulation of the state, the system.
control and regulation of the community or state through
the exercise of the constitutional power of the The [1] ENFORCEMENT OF LAWS as one of the
government. traditional goal of police pillar has been considered as
the prime goal of policing. The police in this regards play
In a narrower sense, POLICE denotes the a major role in fashioning and implementing a proper
constitutionally created agency that exercises the power law enforcement policy for their community. This makes
of the government concerning the maintenance of police as an integral part of the criminal justice system,
tranquility, public order, peace, security of persons and responsible for apprehending offenders and assisting in
property and the protection of public health and morale. their prosecution. According to Charles D. Hale the goals
and objectives of enforcement of law includes the
In a very restricted sense, POLICE refers to that
following: (1) Crime Prevention, (2) Criminal
organization of armed men, which is actually an
Apprehension, (3) Order Maintenance, (4) Public
institution that is capable of exercising legally mandated
Services and (5) Traffic Regulations and Motor Accident
duties to enforce the law, maintain public order, and
Investigation.
detect and prevent crimes.

Evolution of the word police: The second goal of police is the [2] PRESERVATION OF
THE PEACE. This has also been accepted by police as an
The term police came from the GREEK important goal. It is known as the peacekeeping and
word Politeia (government of a city), which was community service roles. Police have the legal authority
used to describe the group of civil officers to arrest individual for disturbing the peace or for
governing the city and not necessarily the armed disorderly conduct. Police are often called to intervenes
men guarding/policing the city. When the not only criminal conduct but also in noncriminal
ROMANS conquered the Greeks, they changed the conduct such as that which occurs at public events, in
word slightly to Politia (civil administration) social relations and in traffic control to maintain law and
which itself derives from the Ancient Greek word order. They often help the people solve problems that
polis (city). The FRENCH changed the word to they cannot cope with alone. This is due to the public
Police and used it to those authorized people who impression that the police are also a SOCIAL
actually enforce the law. The ENGLISH and the SERVANT and a MEDIATOR to domestic problems.
AMERICANS borrowed the word from the French Hence, the public calls the police for their social services
and used it to describe a law enforcement roles, because the police are: (1) constantly available
officer. when needed, (2) dependable when called upon and (3)
capable of providing advice and decision-making
involving interpersonal conflict.
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM. 3

[3] CRIME PREVENTION is the third goal of the police
pillar which closely related to law enforcement and
peace preservation. If the peace has been kept, crime
has, in effect, been prevented. Crime prevention differs
from peacekeeping and law enforcing in that it attempts with neglected children; rendering emergency medical
to eliminate potentially dangerous or criminal
situations. It is PROACTIVE. If police are highly
visible in a community, crime may be prevented. For provides community education programs regarding
example, a routine patrol might not only discover a
crime in progress, but it might also prevent crimes from
being committed. Crime prevention activities are often
undertaken by police include working with juveniles,
cooperating with probation and parole personnel,
educating the public, instigating operation identification
programs providing visible evidence of police authority.
In addition many community services often provided by
police departments aid in crime prevention. This goal
includes the following activities crime detection, crime
investigation, apprehension of suspects and case
preparation. This police activity is directed toward the
identification and apprehension of alleged criminals and
the accumulation, preservation and presentation of
evidence regarding their crimes. The main objective is to
determine who the criminal is and to develops and
present legally accepted evidence to a court of law so
that a conviction is assured.
The fourth traditional goal of the police is the [4]
PROTECTION OF CIVIL RIGHTS AND CIVIL LIBERTIES
which is perceived by some as the single most important ------------------------------------------------------------------------
goal of policing. This goal is acknowledged in the first
paragraph of the Law Enforcement Code of Ethics: “to D. ANCIENT POLICING SYSTEM
respect the constitutional right of all to liberty, equality
and justice.” The authority, goals and methods of the
police promote individual liberty, public safety and
social justice.
In addition to enforcement of laws, preserving the peace,
prevention of crimes protection of civil rights and
liberties, the police are often called on to provide [5]
ADDITIONAL SERVICES to their community as its fifth (GREECE)
and final goal. This role is acknowledged in the first
sentence of the Law Enforcement Code of Ethics: “As a
law enforcement officer, my fundamental duty is to serve
the community”. It is also acknowledged from the
Philippine National Police motto: “To serve and
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
protect”. The police can provides service to the public
such as giving information; directions and advice;
counseling and referring; licensing and registering
vehicles; intervening in domestic arguments; working
or rescue services; dealing with stray animals; and
controlling traffic and crowds. In addition police
crime, drugs, safety and the like.
 THEORIES & CONCEPTS OF POLICE SERVICE
1. Home Rule Theory - The police is considered
servants of the community who depends for the
effectiveness of their functions upon the express
wishes of the people.
2. Continental Theory - Policemen are considered
servants of the higher authority and people have
little or no share of all their duties, nor any direct
connection with them.
3. Old Concept - The old concept of police service
looked upon the police as merely a repressive
machinery.
4. New Concept- regards police as the first line of
defense of CJS, as an organ of crime prevention.
(EGYPT)
1. MEDJAYS - Egyptians (1500 B.C) – Court system
presided by judges appointed by the Pharoah;
Marine patrol & custom house officers protecting
commerce started; first use of dog patrol;
MEDJAYS – civilian police under the command of
a military. Guarding TOMBS.
2. Ancient Greece – EPHORI – law enforcers
4

(ROME)
Ancient Rome – 12 Tabulae (12 TABLES) – the first
written laws, Emperor Augustus – created the:
3. PRAETORIAN GUARD – “emperor’s guard”
4. URBAN COHORTS – “city patrol”
5. VIGILES – “fire fighters”. The first civilian police
force which keep the peace very ruthlessly, hence
the word vigilantes.
(ENGLAND)
6. THANES – It was under King Alfred the Great that
a type of internal police force evolved. Alfred
decreed that the various "thanes" or landowners
throughout his kingdom were responsible to
police his own territory, deliver criminals to the
King and to settle civil litigations.
7. FRANKPLEDGE SYSTEM – Policing was carried
out under a system called frankpledge or mutual
pledge, whereby every male over 12 years old
join nine (9) of his neighbors to form a
Tythingmen – a group of ten (10) men whose duty
was to apprehend any person who offends another
and deliver that offender for trial. Anyone who
failed to join and perform this obligatory duty
was severely fined. Thus, policing responsibility
lies on the hands of the citizens. The head of this
group was referred to as a Tythingman
8. TUN POLICING – Tun was the forerunner of the
word “town“. Under this system, ALL MALE
residents were required to guard the town to
preserve peace and order, protect the life and
properties of the people and other factors that
disturbs the peace and order.
9. HUE AND CRY – In this system, the complainant/
victim goes to the middle of the community and
shouts to call ALL MALE residents to assemble.
The victim reports his complaint to the assembly.
Consequently, all the male residents will go after
the criminal and apprehend him.
10. SHIRE-REEVE SYSTEM – When King William
Norman became the ruler of England, he divided
his kingdom into 55 military districts known as
the Shire-Reeves. SHIRE means a district while
REEVE means the ruler who made laws, pass
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
judgment and impose punishment. He was
assisted by a group of constables, the forerunner
of the constabulary. The term Shire-reeve
eventually became Sheriff, the title of the chief of
constables or police officers in a certain town.
11. TRAVELING JUDGE – was held responsible in
deciding cases that were taken from Shire-reeves
due to some abuses.
12. COURT LEET: to handle local legal matters in
some, but not all, communities, the Normans
established the "Court Leet", which looked after
matters of purely local interest and petty village
nuisances. The head of the Court Leet was the
"COMES STABLE", which was a term that means
"Master of the House". Over a period of time, this
word became "Constable" which is still used
today by members of our modern police forces.
The Comes Stable was often appointed by the
King but was also responsible to keep the peace
and order in a specific area. This appointee was
responsible to local officials who could petition to
have him removed if he did not do his job
properly.
13. KEEPERS OF THE PEACE - In 1195, King Richard
of England issued a proclamation entitled
Keepers of the Peace, requiring the appointment
of Knights to keep the King’s peace by standing
as guards on bridges and gates while checking the
people entering and leaving the cities and towns
14. JUSTICE OF THE PEACE was a position given to a
respected citizen, who has the power to arrest,
pursue and imprison the offenders.
15. WATCH AND WARD - Statute of
Winchester(1285) was enacted for law and
order by king Edward. This law introduced the
system of “WATCH AND WARD”. The primary
purpose of the watch and ward was to guard the
city gates at night.
16. NIGHT WATCHMEN or BELLMEN - King Charles
II of England passed a law in 1663 that provided
for the employment of NIGHT WATCHMEN or
BELLMEN to be on duty from sunset to sunrise.
17. BOW STREET RUNNERS - In 1748, Henry
Fielding became the Chief Magistrate at Bow
Street in London. He organized a group of men
5

known as BOW STREET RUNNERS (thief
catchers). He later formed the Bow Street Horse
Patrol whose duty was to patrol the main roads
thus secure the travelers from highwaymen or
highway bandits. In 1751, Henry published a
pamphlet entitled An Inquiry into the Causes of
the Late Increase of Robbers, which called for
many sweeping changes in the laws and the
execution of their laws1. (FRANCE)
NOTA BENE: Bow Street Runners is the First
modern detective force. It is a small group of
volunteers/non-uniformed homeowners often
called "Take Thieves". They hurry to scene of
crime and begin investigation.
18. SCOTLAND YARD - The British statesman SIR
ROBERT PEEL passed with the parliament the
Metropolitan Police Act on September 29,
1829 established the LONDON METROPOLITAN
POLICE, which became the world's first modern
organized police force. It was later called
SCOTLAND YARD. It became model for the
American police system but also had great
influence on the style of policing in almost all
industrial societies. The Metropolitan Police
force was guided by the concept of crime
prevention as a primary police objective. The
force became the model for other police forces
in Great Britain. Informal names are, "the Met"
and "MPS". In statutes it is referred to in the
lower case as the "metropolitan police force"
or the "metropolitan police", without the
appendage "service". The MPS is also referred to
as Scotland Yard after the location of its original
headquarters. The development of the British
police system is especially significant because
the pattern that emerged not only became a
model for the American police system but also
had great influence on the style of policing in
almost all industrial societies.
Police are often referred to as ´BOBBIES´ or
'PEELERS' after Sir Robert (Bobby) Peel. The
primary role of the police in Britain was to keep
the Queen's Peace, which continues into the
present day.
He also introduced the techniques in
detecting crimes such as detectives concealing
themselves, and secretly photographing and
1
Eduardo, 2008, Notes in Law Enforcement Administration
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
recording conversations. London Metropolitan
Police employed the first undercover officer.
The great contributions of Sir ROBERT PEEL led
people to regard him the FATHER OF MODERN
POLICING. His most memorable principle was,
"the police are the public, and the public are
the police”
19. OFFICERS DE PAIX - In Paris, the position
OFFICERS DE PAIX (origin of “Peace Officer”)
was formed in 1791. This was the origin of the
term Peace Officers
20. SERGENT de VILLE - The French were the first
to establish UNIFORMED POLICE OFFICERS –
they were called SERGENT de VILLE (servant of
the city).
Other contributions of the French in the
development of policing system were:
1. Conceiving street signs.
2. Assigning house numbers.
3. Installing street lighting.
4. Creating emergency and rescue
services.
5. Use of police ambulances.
6. Use of “warrant card”, and ID
signifying authority to arrest.
(AMERICA)
21. RATTLEWATCH - Policing system in America
followed the model developed in England, New
York, Boston and Philadelphia organized their
night watchmen, which was similar to the
bellmen created in London during the reign of
King Charles II. These night watchmen were
known as RATTLEWATCH because they carried
rattle while on duty to inform the public of their
watchful presence.
22. “LEATHERMEN” - in 1638, Night-watch was
initiated in Boston, Massachusetts – they were
called “LEATHERMEN”
23. TEXAS RANGERS – in 1835 - Texas Rangers were
organized
6

E. IMPORTANT TERMS
1. COMPARATIVE POLICE SYSTEM
 It is the science and art of investigating and
comparing the police system of nations. It
covers the study of POLICE
ORGANIZATIONS, TRAININGS and
METHODS OF POLICING of various nations.
 Process of outlining the similarities and
differences of one police police system with
the other in order to discover insights in the
field of international policing or coming out
with the best practices in crime prevention
and law enforcement
 Comparative Law Enforcement
Comparative Research Methods
1. “safari” method (a researcher visits another country) or
2. “collaborative” method (the researcher communicates
with a foreign researcher)
------------------------------------------------------------------------
2. COMPARATIVE CRIMINAL JUSTICE
It is subfield of the study of Criminal Justice that
compares justice system worldwide. Such study can
take a descriptive, historical, or political approach .it
studies and differences in structure, goals,
punishment and emphasis on rights as well as the
history and political stature of different systems.
Comparative criminal justice examines the
differences between justice in different kinds of
societies and communities. Those who specialize in
such a field are called comparativists. By studying
the differences in approach, methodology and
effectiveness, they hope to discover better ways of
enforcing laws and ensuring justice for more people.
THREE (3) BASIC FUNCTIONS OF CRIMINAL
JUSTICE SYSTEM
 Policing
 Adjudication
 Corrections
------------------------------------------------------------------------
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
3. COMPARATIVE COURT SYSTEM
Court systems of the world are of two types:
(1) Adversarial, where the accused is innocent
until proven guilty. The U.S. adversarial
system is unique in the world. No other
nation, not even the U.K. places as much
emphasis upon determination of factual guilt
in courtroom as the U.S. does.
(2) Inquisitorial, where the accused is guilty
until proven innocent or mitigated, have
more secret procedures. Outside the U.S.
most trials are concerned with legal guilt
where everyone knows the offender did it,
and the purpose is to get the offender to
apologize, own up to their responsibility,
argue for mercy, or suggest an appropriate
sentence for themselves.
Where lesser rights are granted to the
accused and the written law is taken as
gospel and subject to little interpretation.
------------------------------------------------------------------------
4. COMPARATIVE CORRECTIONAL SYSTEM
Correctional systems worldwide can be easily
distinguished by whether they support corporal
punishment (beatings) or not. Some so-called
“civilized’’ countries claim they are better than the
U.S. because they don’t perform death penalty but
actually practice such corporal punishments as
beatings and whippings. Nations that practice
corporal punishment do tend, however, to have less
of a correctional overcrowding problem. Probation
and parole, where they exist cross-culturally, are
applied to the country’s citizens, and not for
foreigners or immigrants.
-----------------------------------------------------------------------
5. COMPARATIVE JUVENILE JUSTICE SYSTEM
Juvenile justice systems vary widely. Scotland
has the toughest system, regularly sentencing
juveniles to harsh boot camps with a strict military
regimen and force labor. Germany has a juvenile
justice system similar to the U.S., where more
emphasis is upon education as punishment.
7

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6. INTERNATIONAL CRIMINAL JUSTICE
It involves the study and descriptions of one
country’s law, criminal procedure, or justice process
(Erika Fairchild). Comparative criminal justice
system attempts to build on the knowledge of
criminal justice in one country by investigating and
evaluating, in terms of another country, culture, or
institution.
------------------------------------------------------------------------
7. MODEL SYSTEM
Model system is used to describe the countries
being use as topics of discussion. These countries are
chosen not because they are greater than the others but
because they are the focused of comparison being
studied.
------------------------------------------------------------------------
F. TRANSNATIONAL CRIMES
It is a term that has been used in comparative
international criminal justice study in recent years to
reflect the complexity and enormity of global crime
issues. It is defined by the United Nations (UN) offences
whose inception, proportion and/ or direct or indirect
effects involve in more than one country. Examples
are:
 Human trafficking
 Drug trafficking
 Cyber crimes
 Terrorism
 Money laundering
- A transnational organized crime are any of the
following:
1. A crime committed in more than one State.
2. A crime committed in one State but a
substantial part of its preparation, planning,
direction or control takes place in another
State.
3. A crime committed in one State but involves a
criminal group that engages in criminal
activities in more than one State.
4. A crime committed in one State but has
substantial affects in another State or States.
UNTOC Convention art 3.2)
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
Transnational Organized Crime
Transnational organized crime involves the
planning and execution of illicit business ventures
by groups or networks of individuals working in
more than one country. These criminal groups use
systematic violence and corruption to achieve their
goals. Crimes commonly include money laundering
Human smuggling; cybercrime; and trafficking of
humans, drugs, weapons, endangered, body parts, or
nuclear materials.
The Major Transnational Organized Crime
Groups
Transnational criminals often operate in well-
organized groups intentionally united to carry out
illegal actions. Groups typically involve certain
hierarchies and are headed by a powerful leader.
These transnational organized crime groups work to
make a profit through illegal activities. Because
groups operate internationally, their activity is a
threat to global security, often weakening
governmental institutions or destroying legitimate
business endeavors.
Well known organized crime groups include:
 SICILIAN MAFIA (Cosa Nostra)
An Italian Mafia organized crime group
originating in the region of Sicily, dating to the
19th century. The Mafia's core activities are
protection racketeering, the arbitration of
disputes between criminals, and the organizing
and oversight of illegal agreements and
transactions.
 AMERICAN MAFIA (La Cosa Nostra)
Known as the Italian or Italian-American
mafia. The most prominent organized crime
group in the world from the 1920s to the 1990s.
They have been involved in violence, arson,
bombing, torture, loan sharking, gambling, drug
trafficking, health insurance fraud, and judicial
corruption.
 YAKUZA
Japanese criminal group. Often involves
in multinational criminal activities, including
8

human trafficking, gambling, prostitution, and
undermining licit businesses.
 RUSSIAN MAFIA (BRATVA)
Around 200 Russian groups that operate
in nearly 60 countries worldwide. They have
been involved in racketeering, fraud, tax evasion
gambling, and drug trafficking, arson, robbery,
and murder.
 FUK CHING
Chinese organized criminal group in the
United States. They have been involved involved
in smuggling, street violence, and human
trafficking.
 TRIADS
Underground criminal societies based in
Hong Kong. They control secret markets and bus
routes and are often involved in money
laundering and drug trafficking.
 14K GANG AND “WO SING WO”
Triads, such as “Wo Sing Wo” and 14K
are two of the many triads in Hongkong. They
are involved in various activities ranging from
drug trafficking to corruption.
 UNITED BAMBOO GANG
The largest of Taiwan's three main
Triads.
They are involved in drug trafficking,
prostitution, women and child trafficking.
 JAO PHO
Organize crime group in Thailand. They
are often involved in manufacturing and
trafficking methamphetamine
 “NAM CAM GANG”
One of the most noted organized crime
group in Vietnam and known for drug trafficking
and one of the major transit point of drugs in
Laos, Myanmar, China and Taiwan from
Cambodia.
 RED WA
Gangsters from Thailand. They are
involved in manufacturing and trafficking
methamphetamine.
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
HUMAN TRAFFICKING
 Trafficking in persons is the illegal sale or trading
of persons across borders against their will for
financial gain. It is a form of modern – day slavery.
Trafficking organizations prey on individuals who
are poor, often women who are lured with false
promises of good jobs and better lives and, instead,
are forced to work under brutal conditions.
 Trafficking in persons is a crime against humanity.
It further defined for the purposes of commercial
sexual exploitation or force labor: a modern-day
form of slavery. It is the fastest growing criminal
industry in the world, and tied with the illegal arms
industry as the second largest, after the drug trade.
 Trafficking in person is the 2nd largest international
crime. It is second place after drug trafficking as
the most profitable illegal industry in the world.
 The majority of trafficking victims (teenager) are
between 18 and 24 years of age. An estimated 1.2
million children are trafficked each year. Many
trafficking victims have at least middle-level
education. 600,000 to 800,000 people were
trafficked across international borders every year,
of which 70% were women and 50% children –
mostly for commercial sex trade.
Trafficking in Persons Defined
 International Definition
 Trafficking in person is a crime against
humanity. It further defined as act of
recruiting, transporting, transferring,
harboring, or receiving a person through a
use of force, coercion or other means, for the
purpose of exploiting them. Every year,
thousands of men, women and children fall
into the hands of traffickers, in their own
countries and abroad. Every country in the
world is affected by trafficking, whether as a
country of origin, transit or destination for
victims. (United Nation Convention against
Traditional Organized Crime)
 Republic Act No. 9208 Definition
 Trafficking in person is refers to the recruitment,
transportation, transfer or harboring, or receipt
of persons with or without the victim's consent or
knowledge, within or across national borders by
means of threat or use of force, or other forms of
9

coercion, abduction, fraud, deception, abuse of
power or of position, taking advantage of the
vulnerability of the person, or, the giving or
receiving of payments or benefits to achieve the
consent of a person having control over another
person for the purpose of exploitation which
includes at a minimum, the exploitation or the
prostitution of others or other forms of sexual
exploitation, forced labor or services, slavery,
servitude or the removal or sale of organs.
 The recruitment, transportation, transfer,
harboring or receipt of a child for the purpose of
exploitation shall also be considered as
"trafficking in persons" even if it does not
involve any of the means set forth in the
preceding paragraph.
 Republic Act No. 10364 Definition
 Trafficking in Persons – refers to the
recruitment, obtaining, hiring, providing,
offering, transportation, transfer, maintaining,
harboring, or receipt of persons with or without
the victim’s consent or knowledge, within or
across national borders by means of threat, or
use of force, or other forms of coercion,
abduction, fraud, deception, abuse of power or of
position, taking advantage of the vulnerability of
the person, or, the giving or receiving of
payments or benefits to achieve the consent of a
person having control over another person for
the purpose of exploitation which includes at a
minimum, the exploitation or the prostitution of
others or other forms of sexual exploitation,
forced labor or services, slavery, servitude or the
removal or sale of organs.
 "The recruitment, transportation, transfer,
harboring, adoption or receipt of a child for the
purpose of exploitation or when the adoption is
induced by any form of consideration for
exploitative purposes shall also be considered as
‘trafficking in persons’ even if it does not involve
any of the means set forth in the preceding
paragraph.
Elements of Human Trafficking
On the basis of the definition given in the trafficking
in Persons Protocol, it is evident that trafficking in
persons has three constituents’ elements:
 The Act (What is done) - recruitment, obtaining,
hiring, providing, offering, transportation,
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
transfer, maintaining, harboring, or receipt of
persons
 The Means (How it is Done) - Threat or use of
force, coercion, abduction, fraud, deception, abuse
of power or vulnerability, or the giving or
receiving of payments or benefits to achieve the
consent of a person having control over another
person
 The Purpose (Why it is done) – For the purpose
of exploitation, which include exploiting the
prostitution of others, sexual exploitation, forced
labor, slavery, servitude or similar practices and
the removal or sale of organs.
Types of Trafficking in Persons
1. Trafficking of Women For Sexual Exploitation
2. People Smuggling
3. Child Sexual Exploitation
4. Trafficking for Forced Labour/Servitude
5. Trafficking of Organs
HUMAN SMUGGLING
 Human smuggling is the illicit transfer of people
across borders.
Migrant Smuggling Defined
It is the procurement, in order to obtain, directly or
indirectly, a financial or other material benefit, of the
illegal entry of a person into a state party of which
the person is not a national or permanent resident.”
(Article 3 of the UN Protocol against the
Smuggling of Migrants by Land, Air and Sea).
In contrast to Trafficking in Persons, migrant
smuggling varies in one important way –
victimization. In the case of migrant smuggling the
person involved “voluntarily” submits to being
engaged in criminal activity. Factors such as
economic deprivation, political instability, and
ethnic strife, motivate individuals to cross borders in
search of a better life. Restrictions by governments
on the flow of immigration have therefore created a
lucrative business in the form of migrant smuggling.
10

Laws on Human Trafficking in the Philippines
1. Republic Act No. 10364 – the law amending RA
No. 9208. It is otherwise known as the
“Expanded Anti-Trafficking in persons act of
2012.”
2. Republic Act No. 9208 – “Anti-Trafficking in
Persons Act of 2003”. It provides protection and
support to trafficked persons duty of
prosecutors to respect rights of trafficked
persons and provide punishment for traffickers.
3. Republic Act No. 9775 - An Act Defining the
Crime of Child Pornography, Prescribing
Penalties therefor and for other Purposes. It is
otherwise known as the "Anti-Child
Pornography Act of 2009."
4. Republic Act No. 9995 - An Act Defining and
Penalizing the Crime of Photo and Video
Voyeurism, Prescribing Penalties Therefor, and
for Other Purposes. It is otherwise known as the
"Anti-Photo and Video Voyeurism Act of 2009".
5. Republic Act No. 7610- “Special Protection of
Children Against Abuse, Exploitation and
Discrimination Act”.
6. Republic Act No. 8042- “Migrant Workers and
Overseas Filipino Act” World Wide Perspective
1. Middle East - It is the Becka valley of Lebanon is
7. Republic Act No. 6955- “An Act to Declare
Unlawful the Practice of Matching Filipino
Women for Marriage to Foreign Nationals on a
Mail-Order Basis and Other Similar Practices
8. Republic Act No. 10906 - An act providing
stronger measures against unlawful practices,
businesses, and schemes of matching and
offering Filipinos to foreign nationals for
purposes of marriage or common law
partnership, repealing for the purpose RA No.
6955, also referred to as the 'anti-mail order
bride law'" penalizes any person who has in any
way engaged in business to exploit Filipinas to
offer to foreigners for marriage
9. Republic Act No. 8239 - “Philippine Passport
Act of 1996”
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
DRUG TRAFFICKING
 Drug trafficking is also known as illegal drug
trade. It is a global black-market activity
consisting of production distribution packaging
and sale of illegal psychoactive substances. It is
simply smuggling across borders, and
distribution within the demand country. This
applies in the local scene where local producer’s
scout demand areas for their illegal drug trade.
 Drug trafficking involves SELLING drugs and
drugs paraphernalia, whether it is a local
exchange between a user and a dealer or a
major international operation. Drug trafficking
is a problem that affects every nation in the
world and exists on many levels.
 Drug trafficking is the commercial exchange of
drugs and drug paraphernalia. This includes any
equipment used to manufacture illegal drugs or
use them. It is the illegal drug trade or drug
trafficking is a global black market consisting of
the cultivation, manufacture, distribution and sale
of illegal drugs.
considered to be the biggest producer of cannabis
in the middle east. Lebanon is also becoming the
transit country for cocaine for south America to
European illicit drug markets
2. Spain- It is known as the major transshipment
point for international drug traffickers in Europe
and became ‘’the paradise of drug users in
Europe’’.
3. South America- Columbia, Peru Uruguay, and
panama are the principal sources all cocaine
supply in the world due the robust production
of the coca plants source of the cocaine drug.
4. Morocco- It is known in the world to be the
number one producer of marijuana. However,
Mexico is still the major producer of cannabis.
5. Philippines- It is second to Morroco as to the
production of marijuana. It also became major
transshipment point for the world wide of
11

distribution of illegal drug particularly shabu and CYBERCRIMES
cocaine from Taiwan and South America. It is also
noted that Philippines today is known as the
“drug paradise of abusers in Asia”.
6. India- It is the center of the worlds drug map,
leading to rapid addiction among its people.
7. Indonesia -Northern Sumatra has traditionally
been the main cannabis growing area in
Indonesia.
8. Singapore, Malaysia and Thailand- is the most
favorable sights of drug distribution from the
golden triangle and other part of Asia.
9. China - It is the transit route for heroin from
golden triangle to Hong-Kong. It also the country
where ephedra plant is cultivated source of drug
ephedrine- the principal chemical for producing
for drug Shabu.
10. Hongkong- It is the world transshipment point of
all forms of heroin.
11. Japan- It became the major consumer of
cocaine and shabu from the United State and
Europe.
The Laws on Dangerous Drugs in the Philippines
1. R.A. 6425 - Dangerous Drugs Act of 1972
2. R.A. 9165 – Comprehensive Dangerous Drugs
Act of 2002. Approved on June 7, 2002 - Effective
July 4, 2002
3. R.A. 9211 - Known as Tobacco Regulation Act of
2003 - Signed into law in June 2003. The
following are the prohibited Acts:
a. Allowing Children to man stalls selling
tobacco product (s)
b. Selling tobacco products to a minor (under
18 years of age)
c. Selling of Tobacco products within 100
meters from playgrounds, schools and all
youth facilities Cigarette vending machine
also within the place mentioned
d. Smoking in Public Places
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
 Cybercrime is any illegal act committed using a
computer network (especially the Internet).
 Cybercrime is a subset of Computer Crime.
‘Cybercrime encompasses any criminal act
dealing with computers and networks (called
hacking). Additionally, cybercrime also
includes traditional crimes conducted through
the Internet.’
 Cybercrime is an unlawful act wherein the
computer is either a tool or a target or both. The
term used to denote the use of computer
technology to engage in unlawful activity.
 Cyber Crime is a term used to broadly describe
criminal activity in which computers or
computer networks are a tool, a target, or a place
of criminal activity and include everything from
electronic cracking to denial of service attacks. It
is also used to include traditional crimes in
which computers or networks are used to enable
the illicit activity
Cyber
· Refers to a computer or a computer network, the electronic medium in
which online communication takes place.
Hacking or Cracking
- the unauthorized access into or interference in a computer system,
server, or information and communication system; or any access in
order to corrupt, alter, steal, or destroy using a computer or other
similar information and communication devices, without the knowledge
and consent of the owner (e.g. Denial of Service Attack; Virus
Dissemination; Web Defacement)
Phishing
· a form of identity theft in which scammers send an e-mail message that
appears to come from a legitimate enterprise.
Pharming
- a cyberattack intended to redirect a website's traffic to another, fake
site. Pharming attacks compromise at the DNS server level, re-directing
you to a hacker's site when you type in a company's Web address.
Philippine Laws on Cyber Crime
1. Republic Act no. 10175 - Cyber Crime Law of
2012
2. Republic Act No. 9775 - An Act Defining the
Crime of Child Pornography, Prescribing
Penalties Therefor and for other Purposes
3. Republic Act No. 9995 - An Act Defining and
Penalizing the Crime of Photo and Video
12

Voyeurism, Prescribing Penalties Therefor, and
for Other Purposes
TERRORISM
 The use of violence and threats to intimidate or
coerce especially for political purposes.
 Terrorism is the systematic use of terror,
especially as a means of coercion. It refers only to
those acts which are:
 Intended to create fear
 Are perpetrated for ideological goal
 Deliberately target non-combatants
 Common definitions of terrorism refer only to
those violent acts which are intended to create
fear (terror), are perpetrated for a religious,
political or ideological goal, and deliberately
target or disregard the safety of non-combatants
(civilians).
**Under Section 3 of R.A. 9372, otherwise known as
the Human Security Act of 2007, TERRORISM is the
act of any person who commits an act punishable
under any of the following provisions of the revised
penal code:
 Art 122(Piracy and Mutiny)
 Art 134 (Rebellion and Insurrection)
 Art 134-a (Coup d etat)
 Art 248 (Murder)
 Art 267 (Kidnapping and serious illegal
detention)
 Art 324 (Crimes Involving Destruction)
Or under:
 PD 1613 (The Law on Arson)
 R.A. 6969 (Toxic Substance Control Act)
 R.A. 5207 (Atomic Energy Regulatory Act)
 R.A. 6235 (Anti-Hijacking Law)
 PD 532 (Anti-Piracy and Highway Robbery)
 PD1866 (Illegal Possession of Fire Arms)
thereby sowing and creating a condition of
widespread and extraordinary fear and panic
among populace, in order to coerce the
government to give in to an unlawful demand
shall be guilty of the crime of terrorism and shall
suffer the penalty of 40 years of imprisonment MONEY LAUNDERING
without the benefit of parole
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
**Under Section 4 of R.A. 11479, otherwise known as
the “The Anti-Terrorism Act of 2020”, TERRORISM is
committed by any person, who within or outside the
Philippines, regardless of the stage of execution:
a) Engages in acts intended to cause death or
serious bodily injury to any person or endangers
a person's life;
b) Engages in acts intended to cause extensive
damage or destruction to a government or public
facility, public place, or private property;
c) Engages in acts intended to cause extensive
interference with, damage, or destruction to
critical infrastructure;
d) Develops, manufactures, possesses, acquires,
transports, supplies or uses weapons, explosives
or of biological, nuclear, radiological or chemical
weapons; and
e) Release of dangerous substances or causing fire,
floods or explosions
when the purpose is to intimidate the general
public, create an atmosphere of fear or to spread a
message of fear, to provoke or influence by
intimidation the government or any international
organization, seriously destabilize or destroy the
fundamental political, economic, or social structures
in the country, or create a public emergency or
seriously undermine public safety.
The definition further states that "advocacy, protest,
dissent, stoppage of work, industrial or mass action,
and other similar exercises of civil and political rights"
shall not be considered as terrorist acts ONLY if
they "are not intended to cause death or serious
physical harm to a person, to endanger a person's life,
or to create a serious risk to public safety."
Penalty: Life imprisonment without the benefit of
parole.
 Money laundering is the process of creating the
appearance that large amounts of money obtained
from illegal means.
13
 Isabela State University | ECHAGUE
College of Criminal Justice Education
Three (3) Basic Steps to change Illicit Funds to economy, where they can be invested and
Legitimate Funds spent freely.

1. Placement– This is the first step of the money-
laundering process and the ultimate aim of this
phase is to remove the cash from the location of
acquisition so as to avoid detection from the
authorities. It involves a changing the bulk cash
derived from criminal activities into a more
portable and less suspicious form, then getting
those proceeds into the mainstream financial
system.
Example: Dividing large amount of money into less
smaller terms that are deposited directly into
different bank account.
- Laundered funds are made available for
activities such as investment in legitimate
or illegitimate businesses, or spent to
promote the criminal's lifestyle. At this
stage, the illegal money has achieved the
appearance of legitimacy. It should be
noted that not all money laundering
transactions go through this three-stage
process. Transactions designed to launder
funds can also be affected in one or two
stages, depending on the money laundering
technique being used.

2. Layering – Layering involves moving funds Example: Purchase or resale of real estate,
around the financial system, often in a complex investment in securities etc. or funnel such money
serious of transactions to create confusion and into various dummy firms and get repaid
complicate the paper trail. through salaries, rent,– COLLEGE
ISABELA STATE UNIVERSITY andOF CRIMINAL
leasJUSTICE
onEDUCATION
non- existing
- It involves the movement of these funds, assets. ORGANIZED CRIME INVESTIGATION
by: Reginald C. Sibug, MSCrim.
often mixed with funds of legitimate origins,
A typical Money Laundering Scheme
through the world’s financial systems in
numerous accounts in an attempt to hide 1
the funds back into the mainstream PREDICATE CRIME
economy, where they can be invested and
spent freely.
- To conceal the illegal origin of the placed
2
funds and thereby make them more useful, PLACEMENT
the funds must be moved, dispersed and
disguised i.e. layering.
- At this stage, money launderers use many
Dirty money integrates into the
different techniques to layer the funds in financial system
order to disguise their origins. Collection of Dirty money
3 LAYERING

Example: (1) having professionals act as Transfer on the

bank account of
intermediaries and transacting through company X.

corporations and trusts, (2) transferring funds to

numerous accounts in one or more financial
institutions. (3) Movements of money into Loan to
different accounts and different countries. Company
Y
Payment by Y of
false invoice to
Wire Transfer
3. Integration – The ultimate goal of money company X

laundering process is integration. Once the funds Purchase of luxury asset,

financial investment and
are in the financial system and insulated through commercial and industrial Offshore Banking
the layering stage, the integration stage is used investment

to create the appearance of legality through

additional transactions.
4 INTEGRATION

- It is the process of reintroducing these

layered funds back into the mainstream

COMPARATIVE MODELS IN POLICING

Reginald C. Sibug, MS CRIM. 14
 Isabela State University | ECHAGUE
College of Criminal Justice Education

ACTIVITIES
Learning Task #1

1. Base on the definition of Comparative Police

System, as future law enforcers, what do you think
are the importance of studying it?

2. Give hypothetical examples of the following

theories and concepts in policing:
a. Home Rule Theory
b. Continental Theory
c. Old Concept
d. New Concept

ACADEMIC REQUIREMENT #1b:

“TRANSNATIONAL CRIMES”
 Watch the following videos and make a
reaction paper about the content of the
said videos. Write first the name/title of
each videos before your
answers(“reaction/comments”).
a. https://www.youtube.com/watch?v=Ozty0bdayvg
b. https://www.youtube.com/watch?
v=3jPoS1TZ6fU&pbjreload=101
c. https://www.youtube.com/watch?v=1ObJPaSZxCs
d. https://www.youtube.com/watch?v=8KseFc_v-k4

COMPARATIVE MODELS IN POLICING

Reginald C. Sibug, MS CRIM. 15