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UNITED STATES VS.

BULL (1910)
Petitioners: UNITED STATES, plaintiff & appellee
Respondents: H. N. BULL, defendant & appellant
Territoriality
SUMMARY: Bull transported 667 cattle with no stalls from Formosa to Manila. He was convicted
for not providing suitable means of transporting such animals while in transit, because he
committed the offense within Philippine waters.
FACTS:

Bull transported 667 cattle on Standard, a Norwegian steamship, from Ampieng,


Formosa, to Manila
Some cattle were tied through rings in their noses, while some roamed freely upon deck
He was convicted of a violation of Sec. 1, Act No. 55 as amended by Sec. 1, Act No.
275, for not providing suitable means of transporting such animals while in transit
Bull appealed the decision of the Court of First Instance

ISSUE/S:

WoN the Philippines has jurisdiction over the occurrences on the Standard
o YES. Act No. 55 confers jurisdiction to Courts of First Instance or any provost
court organized in the province/port where said animals are disembarked.
Forbidden act was done within American waters (3 miles from the headlands),
and Standard travelled 25 miles from that demarcation before disembarkation
during which violation continued. US follows English theory: when a merchant
vessel enters a foreign port, it is subject to the jurisdiction of the local
authorities.Commerce treaty between US and Sweden and Norway: No
jurisdiction except when ship members disturb order or tranquility of country, but
any violation of criminal laws disturbs the order or tranquility of the country.
WoN complaint against Bull was defective
o NO. Defendant says complaint does not allege that animals were disembarked at
port of Manila. But disembarkation of animals is not necessary to violate Act No.
55. Defendant also says complaint only alleges that he willfully violated Act No.
55, not knowingly. But to willfully do an act implies that it was done for a set
purpose; it would follow that it was knowingly done. Defendant asserted that in
his experience, his way of transporting cattle is preferable and more secure to
life/comfort of animals, which further proves that he did it knowingly and
intentionally.
WoN Act No. 55 as amended violates the US Constitution
o NO. Philippines doesnt follow US constitution; it follows its own constitution that
the US Congress made for the Philippines. Philippine Legislature was given
general legislative power only subject to 1) the restrictions of its US Congressmade constitution and 2) annulment by US Congress (Philippine legislation is
valid until annulled by Congress).
WoN Bull provided suitable means of transporting animals

NO. Judgment of whether a certain method is suitable should be left to the


courts, not the master of the ship. Testimony of experienced captain: A suitable
manner is by way of individual stalls, this results in no loss of cattle whatsoever.
Trial court found these facts: upon disembarkation, 15 cattle had broken legs and
3 cattle were dead. There were no stalls.

NOTES:

Read page 29 of Reyes. Offenses committed on board a foreign merchant vessel while
on Philippine waters are triable before our court.
Act/Omission: not providing suitable means of transporting cattle
Defined in Law: Act No. 55 as amended by Act No. 275
Intent: Bull knowingly and willfully did the act