THE UNITED STATES, plaintiff-appellee, vs. H. N.

BULL, defendant-appellant
G.R. No. L-5270 (January 15, 1910)

FACTS:
H.N. Bull appealed to the Supreme Court after having been convicted in the Court of First
instance of a violation of Section 1 Act No.55 as amended by Section 1 Act No. 275 of the
Philippine Commission.
On December 2, 1908, a Norwegian steamship vessel engaged in the transport of animals named
Stanford commanded by H.N. Bull docked in the port of Manila, Philippines. It was found that
said vessel from Ampieng, Formosa carried 677 heads of cattle without providing appropriate
shelter and proper suitable means for securing the animals which resulted for most of the animals
to get hurt and others to have died while in transit. Appellant contends that the information is
insufficient because it does not state that the court was sitting at a port where the cattle were
disembarked, or that the offense was committed on board a vessel registered and licensed under
the laws of the Philippine Islands.
ISSUE:
WON the court had jurisdiction over an offense committed on board a foreign ship while inside
the territorial waters of the Philippines.
RULING:
The Supreme Court speaking through Justice Elliot stated that no court of the Philippines has
jurisdiction over any crimes committed in a foreign ship on the high seas, but the moment it
entered into territorial waters, it automatically would be subject to the jurisdiction of the country.
Every state has complete control and jurisdiction over its territorial waters. In the case at bar, the
Norwegian vessel came within 3 miles of a line drawn from the headlines which embrace the
entrance to Manila Bay. Hence, she was within territorial waters. As such, the ship and her crew
were then subject to the jurisdiction of the territorial sovereign. The offense, assuming that it
originated at the port of departure in Formosa, was a continuing one, and every element
necessary to constitute it existed during the voyage across the territorial waters. The completed
forbidden act was done within American waters, and the court therefore had jurisdiction over the
subject-matter of the offense and the person of the offender.
Based on these reasons, 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.