Criminal Law I Case Digest Prepared by: Cedric

US v. Bull
TOPIC: Applicability of Provisions

Court EN BANC

Citation G.R. No. 5270

Date July 31, 1970

Petitioner The United States

Respondent HN Bull

Ponente Elliott, J.

Doctrine

Case Summary

H.N. Bull was the master of a steam sailing ship which carried and transported cattle, carabaos,
and animals to the city of Manila. The ship docked to Manila port with animals in unfavorable
conditions. The respondent was charged of violation of the provisions of Acts No. 55. Given that the
vessel was a foreign one, and it disembarked from Vermosa, the respondent contends that the
Philippine court cannot confer jurisdiction over the case.

FACTS

● For many months to December 2, 1908, H.N. Bull was the master of a vessel sailing from
Ampieng, Vermosa to the port of Manila, PH.
o The Ship was a Norwegian Vessel
o It was not registered or licensed in the Philippine Islands
● The vessel carried cattle, carabaos, and other animals in without providing proper care and
appropriate shelter.
● This resulted in animals getting hurt and others dying while in transit.
● As the master of the ship. H.N. Bull was alleged to have “willfully, unlawfully, and wrongfully”
carry these animals under harsh conditions.
● This cruelty is contrary to the provisions of Act No. 55 the Philippine Commission.
● However, the respondent contends that the complaint cannot be filed because:
o The complaint does not state facts sufficient to confer jurisdiction.
o The PH trial court has no jurisdiction over the case.
o Act No. 55 as amended is in violation of certain provisions of the Constitution of the
United States and void as applied to the facts of this case.
Criminal Law I Case Digest Prepared by: Cedric
US v. Bull
TOPIC: Applicability of Provisions

ISSUE - HELD - RATIO:

ISSUE # 1 HELD

WON the Philippine Court had a jurisdiction over these acts that were YES
committed on a foreign ship inside the waters of the Philippines.

RATIO

● No court of the Philippine Islands had jurisdiction over an offenses or crime committed on the
high seas or within the territorial waters of any other country, BUT when the respondent
came within 3 miles of a line drawn from the headlines which embrace the entrance to
Manila Bay, he was within territorial waters, and a new set of principles became
applicable.
● From outside to within the territorial waters, the vessel’s voyage the violation of the statue
continued, and as far as the jurisdiction of the court is concerned, it is immaterial that the
same conditions may have existed while the vessel was on the high seas.
● The completed forbidden act was done within the territorial waters of the Philippines,
and the court therefore had jurisdiction over the subject-matter of the offense and the
person of the offender.

ISSUE - HELD - RATIO:

ISSUE # 1 HELD

WON the evidence was sufficient to confer jurisdiction to hear and determine YES
the case

RATIO

● The respondent contends that the case is defective because it does not allege that the animals
disembarked from the port of Manila. This allegation, as the respondent claims, is essential to
jurisdiction of the court of the Philippines.
● Disembarkation is immaterial. It is not necessary in order to constitute the completed offense
– which was done in the territorial waters of the Philippines.
● The evidence shows not only that the defendant’s acts were knowingly done, but his defense
rests upon the assertion that “according to his experience, the system of carrying cattle loose
upon the decks and in the hold is preferable and more secure to the life and comfort of the
animals.”
● It was conclusively proven that what was done was done knowingly and intentionally.
Criminal Law I Case Digest Prepared by: Cedric
US v. Bull
TOPIC: Applicability of Provisions

ISSUE - HELD - RATIO:

ISSUE # 1 HELD

WON the defendant violated the Act No. 55 YES

RATIO

● Act No. 55 of Section 1 provides that "the owners or masters of vessels, carrying or
transporting cattle, or other animals, from one port in the Philippine Islands to another, or from
any foreign port to any port within the Philippine Islands, shall carry with them, sufficient forage
and fresh water to provide for the suitable sustenance of such animals during port of
debarkation, be provided with adequate forage and fresh water at least once in every twenty-
four hours from the time that the animals are embarked to the time of their final debarkation".

● Section 3 of Act No. 55 mentioned "Any owners of animals, who knowingly and willfully fails to
comply with the provisions of section one, shall, for every such failure, be liable to pay a
penalty"

● It was conclusively proven, based on the evidence, done knowingly and intentionally.

RULING:

WHEREFORE, 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. The sentence and
judgment is affirmed. So ordered.