LAW 100 Case Digest Prepared by: Byron

Case Title People V. Wong Cheng

TOPIC: Territoriality and Jurisdiction of the Courts

Court SC Citation GR 18294 Date Oct 19, 1922

Petitioner People of the Philippine Islands

Respondent Wong Cheng

Ponente Justice Norberto Romualdez

Doctrine

Doctrine of Territoriality

Case Summary

Defendant was accused of illegally smoking opium aboard a merchant vessel while anchored in Manila.
Defendant filed a demurrer and alleged that the court had lack of jurisdiction because it was committed
aboard a merchant vessel of foreign nationality. The Attorney-General appealed to the supreme court who
eventually overturned the lower court’s decision, citing the Philippines’ conformance to the English rule
based on the territorial principle, and how it goes against public peace.

FACTS

ANTECEDENT FACTS
● Appelle is accused of having illegally smoked opium aboard the English merchant vessel Changsa
while it was anchored inside Manila Bay, two and a half miles from the shores of the city
● The Court of First Instance of Manila sustained the demurrer presented by the defendant which cited
the court’s lack of jurisdiction on the matter.
● Attorney-General thus appealed to the Supreme Court and urged for the revocation of said ruling

ISSUE - HELD - RATIO

ISSUE #1 HELD

Whether or not the court has jurisdiction over a crime committed on merchant YES
vessels anchored in jurisdictional waters

RATIO

1. There exists two doctrines which guide such particular matters: (1) French, which gives the
jurisdiction to the nationality of the merchant vessel, (2) English, which gives jurisprudence to where
the crime was committed
2. In the comity of nations, even the U.S. may submit to the French rule. However it is not always easy
to distinguish which one to obey, but the U.S. court has held that so long as it disturbs public peace
then it shall be suppressed and is under local jurisdiction and juridiciality.
3. The Philippines, being a U.S. colony, follows U.S. jurisprudence, and thus obeys the territorial
principle espoused by England and the United States, wherein crimes committed on board merchant
 vessels should be justiciable within the courts of the country where crime was committed
a. Although the mere possession of Opium aboard a foreign vessel in transit has been declared
by this court as non-triable, its mere possession and non-use within our territory avoids the
violation of our statutes and is not a disturbance of public order.

RULING: Order appealed is thus REVOKED, and the cause ordered remanded to the court of origin for
further proceedings in accordance with the law, without special findings as to costs. So ordered.