Illuh Asaali vs Commissioner of Customs

In 1950, customs officers intercepted 5 ships owned by Illuh Asaali et al. Said ships were found to be from Borneo and
were on their way to a port in Tawi-tawi, Sulu. On board the ships were rattan products and cigarettes. The customs
confiscated said items on the ground that Asaali et al do not have the required import permits for the said goods.
Asaali questioned the legality of the seizure as he contended that the customs officers did not intercept them within
Philippine waters but rather, they were intercepted in the high seas. Hence, according to Asaali, Philippine import laws
have no application to the case at bar.
ISSUE: Whether or not Asaali’s contention is correct.
HELD: No. Asaali’s contention is without merit. The Revised Penal Code leaves no doubt as to its applicability and
enforceability not only within the Philippines, its interior waters and maritime zone, but also outside of its jurisdiction
against those committing offense while on a Philippine ship. The ships intercepted were of Philippine registry.
Further, it has been an establish principle that a state has the right to protect itself and its revenues, a right not limited
to its own territory but extending to the high seas. The authority of a nation within its own territory is absolute and
exclusive. The seizure of a vessel within the range of its cannon by a foreign force is an invasion of that territory, and
is a hostile act which it is its duty to repel. But its power to secure itself from injury may certainly be exercised beyond
the limits of its territory.